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Court Dockets
U.S. District Court
District of Columbia (Washington, DC)
CIVIL DOCKET FOR CASE #: 1:19-cv-00945-RDM
District of Columbia (Washington, DC)
CIVIL DOCKET FOR CASE #: 1:19-cv-00945-RDM
TOLTON et al v. JONES DAY
DOCKET INFORMATION
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| Plaintiff |
NILAB RAHYAR TOLTON
Plaintiff
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| Representation | |||
| Clare J. Horan SANFORD HEISLER SHARP LLP 111 S. Calvert Street Suite 1950 Baltimore, MD 21202 (410) 834-7421 choran@sanfordheisler.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED | Deborah Kristine Marcuse SANFORD HEISLER SHARP, LLP 111 South Calvert Street Suite 1950 Baltimore, MD 21202 (410) 834-7415 dmarcuse@sanfordheisler.com LEAD ATTORNEY ATTORNEY TO BE NOTICED | Whittney Barth SANFORD HEISLER SHARP 111 S. Calvert St Ste 1950 Baltimore, MD 21202 (410) 834-7424 Fax: (410) 834-7425 wbarth@sanfordheisler.com LEAD ATTORNEY ATTORNEY TO BE NOTICED | |
| Kate MacMullin SANFORD HEISLER SHARP, LLP 1350 Avenue of the Americas 31st Floor New York, NY 10019 (347) 417-1595 kmacmullin@sanfordheisler.com PRO HAC VICE ATTORNEY TO BE NOTICED | Katie Marie Mueting SANFORD HEISLER SHARP, LLP 700 Pennsylvania Ave, SE Suite 300 Washington, DC 20003 (202) 499-5206 Fax: (202) 499-5199 kmueting@sanfordheisler.com ATTORNEY TO BE NOTICED | Paul Blankenstein SANFORD HEISLER SHARP 700 Pennsylvania Ave, SE Suite 300 Washington, DC 20003 (202) 499-5213 Fax: (202) 499-5199 pblankenstein@sanfordheisler.com TERMINATED: 10/01/2020 ATTORNEY TO BE NOTICED | |
| Russell L. Kornblith SANFORD HEISLER SHARP, LLP 1350 Avenue of the Americas 31st Floor New York, NY 10019 (646) 402-5646 Fax: (646) 402-5651 rkornblith@sanfordheisler.com PRO HAC VICE ATTORNEY TO BE NOTICED | |||
| Defendant |
JONES DAY A General PartnershipDefendant
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| Representation | |||
| Beth Rochelle Heifetz JONES DAY 51 Louisiana Avenue, N.W. Washington, DC 20001 (301) 913-9328 Fax: (202) 626-1700 bheifetz@jonesday.com LEAD ATTORNEY ATTORNEY TO BE NOTICED | Adrian Wager-Zito ADRIAN WAHER-ZITO 51 Louisiana Avenue, N.W. Washington, DC 22201-2113 (202) 879-3939 adrianwagerzito@jonesday.com ATTORNEY TO BE NOTICED | Jacob M. Roth JONES DAY 51 Louisiana Avenue, NW Washington, DC 20001 (202) 879-7658 Fax: (202) 626-1700 yroth@jonesday.com ATTORNEY TO BE NOTICED | |
| Kate Wallace JONES DAY - BOSTON 100 High Street 21st Floor Boston, MA 02110 (617) 449-6893 kwallace@jonesday.com PRO HAC VICE ATTORNEY TO BE NOTICED | MaryEllen Powers JONES DAY 51 Louisiana Avenue, NW Washington, DC 20001-2113 (202) 879-3870 Fax: (202) 737-2832 mepowers@jonesday.com ATTORNEY TO BE NOTICED | Rebekah B. Kcehowski JONES DAY One Mellon Bank Center 500 Grant Street Suite 4500 Pittsburgh, PA 15219 (412) 394-7935 Fax: (412) 394-7959 PRO HAC VICE ATTORNEY TO BE NOTICED | |
| Terri L. Chase JONES DAY 600 Brickell Avenue Suite 3300 Miami, FL 33131 (305) 714-9722 Fax: (305) 714-9799 tlchase@jonesday.com PRO HAC VICE ATTORNEY TO BE NOTICED | |||
| Amicus |
JULIA SHEKETOFF
Amicus
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| Representation | |||
| JULIA SHEKETOFF 2207 Combes Street Urbana, IL 61801 (617) 470-5284 sheketoff@gmail.com PRO SE | |||
Numbers shown are court assigned numbers.
| Entry | Filed | Description | |
|---|---|---|---|
| 1 | Apr 3, 2019 | View | MOTION to Proceed Under Pseudonym by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(jf). Added MOTION for Order on 4/3/2019 (ztd). (Entered: 04/03/2019) |
| 2 | Apr 3, 2019 | View | ORDER granting 1 Motion for Leave to Proceed Under Pseudonym. Signed by Chief Judge Beryl A. Howell on 04/03/2019. (see order for full detail) (jf) (Entered: 04/03/2019) |
| 3 | Apr 3, 2019 | Request | SEALED Declaration filed by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON. (This document is SEALED and only available to authorized persons.)(zjf) (Entered: 04/03/2019) |
| 4 | Apr 3, 2019 | View | COMPLAINT against JONES DAY ( Filing fee $ 400, receipt number 4616097419) with Jury Demand filed by NILAB RAHYAR TOLTON, ANDREA MAZINGO, JANE DOES 1-4. (Attachments: # 1 Civil Cover Sheet)(jf) (Entered: 04/03/2019) |
| 5 | Apr 3, 2019 | View | MOTION To Seal Portions Of The Record by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON (Attachments: # 1 Text of Proposed Order)(jf) (Entered: 04/03/2019) |
| 6 | Apr 3, 2019 | View | MOTION for Protective Order Sealing Portions Of The Court Record by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON (jf) (Entered: 04/03/2019) |
| 7 | Apr 3, 2019 | View | STANDING ORDER: The parties are hereby ORDERED to comply with the directives set forth in the attached Standing Order. See document for details. Signed by Judge Randolph D. Moss on 4/3/2019. (lcrdm2, ) (Entered: 04/03/2019) |
| Apr 9, 2019 | MINUTE ORDER: In ruling on Plaintiffs' prior Motion to Proceed Under Pseudonyms, Dkt. 1, Chief Judge Howell ordered that Exhibit A to Plaintiffs' motion "remain under seal until further order of the Court" subject to "any further consideration by the United States District Judge to whom this case is randomly assigned." Dkt. 2 at 7. Following that memorandum opinion and order, Plaintiffs filed a "Notice of Motion to Seal Portions of the Record," Dkt. 5, as well as a separate motion "seeking a protective order" to seal "Exhibit A... to the Jane Doe Plaintiffs' Motion to Proceed Under Psedonyms [Dkt. 1]," Dkt. 6. Because the Notice of Motion to Seal Portions of the Record, Dkt. 5, references a "memorandum in support filed with it" but contained no attachment nor identified any portion of the record to be sealed, the Court understands that document to seek the same relief identified in Dkt. 6. To the extent that both motions seek an order that Exhibit A to Plaintiffs' Motion to Proceed Under Pseduonym, Dkt. 3, shall remain sealed, it is hereby ORDERED that the motions are GRANTED. Having reviewed the record, Plaintiffs' motions to date, and Chief Judge Howell's memorandum opinion and order, the Court agrees that Plaintiffs' significant interest in maintaining their anonymity at this stage of the litigation is sufficient to overcome any general presumption in favor of open proceedings. See United States v. Hubbard, 650 F.2d 293, 317-321 (D.C. Cir. 1980). Accordingly, for the reasons set forth in Chief Judge Howell's memorandum opinion and order, it is hereby ORDERED that Exhibit A to the Jane Doe Plaintiffs' Motion to Proceed Under Pseudonyms shall remain sealed pending further order of the Court and that Defendant is prohibited from publicly disclosing the Plaintiffs' identities or any personal identifying information that could lead to the identification of the Plaintiffs by non-parties. Signed by Judge Randolph D. Moss on 4/9/2019. (lcrdm2, ) (Entered: 04/09/2019) | ||
| 8 | May 3, 2019 | Request | ERRATA Amended Caption and Signature Pages by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON 4 Complaint filed by ANDREA MAZINGO, NILAB RAHYAR TOLTON, JANE DOES 1-4. (Attachments: # 1 Errata Amended Caption Page, # 2 Errata Amended Signature Page)(Marcuse, Deborah) (Entered: 05/03/2019) |
| 9 | May 6, 2019 | View | NOTICE of Filing Consent Forms by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON (Attachments: # 1 Notice and Consent, # 2 Notice and Consent, # 3 Notice and Consent, # 4 Notice and Consent, # 5 Notice and Consent, # 6 Notice and Consent)(Marcuse, Deborah) (Entered: 05/06/2019) |
| 10 | May 20, 2019 | View | NOTICE of Appearance by Beth Rochelle Heifetz on behalf of JONES DAY (Heifetz, Beth) (Entered: 05/20/2019) |
| 11 | May 20, 2019 | View | MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Terri L. Chase, :Firm- Jones Day, :Address- 250 Vesey Street New York, NY 10281. Phone No. - (212) 326-3939. Fax No. - (212) 755-7306 Filing fee $ 100, receipt number 0090-6133325. Fee Status: Fee Paid. by JONES DAY (Attachments: # 1 Declaration, # 2 Text of Proposed Order)(Heifetz, Beth) (Entered: 05/20/2019) |
| 12 | May 20, 2019 | View | MOTION Compel Compliance with Federal Rule 10(a) by JONES DAY (Attachments: # 1 Declaration, # 2 Exhibit 1 to Declaration, # 3 Exhibit 2 to Declaration, # 4 Exhibit 3 to Declaration, # 5 Exhibit 4 to Declaration, # 6 Text of Proposed Order)(Heifetz, Beth) (Entered: 05/20/2019) |
| 13 | May 20, 2019 | View | NOTICE of Appearance by MaryEllen Powers on behalf of JONES DAY (Powers, MaryEllen) (Entered: 05/20/2019) |
| May 20, 2019 | MINUTE ORDER: Upon consideration of the Motion for Leave to Appear Pro Hac Vice, Dkt. 11, it is hereby ORDERED that the motion is GRANTED. Terri L. Chase may appear pro hac vice in this matter. Signed by Judge Randolph D. Moss on 5/20/2019. (lcrdm2, ) (Entered: 05/20/2019) | ||
| May 20, 2019 | MINUTE ORDER: It is hereby ORDERED that Plaintiffs shall file a response to Defendant's motion to Compel Compliance with Federal Rule 10(a), Dkt. 12, on or before May 23, 2019. It is further ORDERED that, if Plaintiffs have not already done so, Plaintiffs shall provide Defendant with a copy of the sealed declaration in support of Plaintiffs' Motion to Proceed Under Pseudonym, Dkt. 3. Signed by Judge Randolph D. Moss on 5/20/2019. (lcrdm2, ) (Entered: 05/20/2019) | ||
| May 20, 2019 | Set/Reset Deadlines: Plaintiffs shall file a response to Defendant's motion to Compel Compliance with Federal Rule 10(a), Dkt. 12, on or before 5/23/2019. (kt) (Entered: 05/20/2019) | ||
| 14 | May 23, 2019 | View | Memorandum in opposition to re 12 MOTION Compel Compliance with Federal Rule 10(a) filed by JANE DOES 1-4. (Attachments: # 1 Declaration of Deborah K. Marcuse, # 2 Exhibit A to Marcuse Declaration, # 3 Exhibit B to Marcuse Declaration, # 4 Exhibit C to Marcuse Declaration)(Marcuse, Deborah) (Entered: 05/23/2019) |
| May 24, 2019 | MINUTE ORDER: It is hereby ORDERED that the parties shall meet and confer with regard to Plaintiffs' pseudonymity. It is further ORDERED that the parties shall appear for a hearing on the Motion to Compel Compliance with Federal Rule 10(a), Dkt. 12, at 2:45 p.m. on May 28, 2019 in Courtroom 21. Signed by Judge Randolph D. Moss on 5/24/2019. (lcrdm2, ) (Entered: 05/24/2019) | ||
| May 24, 2019 | Set/Reset Hearings: Motion Hearing set for 5/28/2019, at 2:45 PM, in Courtroom 21, before Judge Randolph D. Moss. (kt) (Entered: 05/24/2019) | ||
| 15 | May 24, 2019 | View | REPLY to opposition to motion re 12 MOTION Compel Compliance with Federal Rule 10(a) filed by JONES DAY. (Attachments: # 1 Declaration of Terri Chase)(Powers, MaryEllen) (Entered: 05/24/2019) |
| May 28, 2019 | MINUTE ORDER: It is hereby ORDERED that the motions hearing scheduled for May 28, 2019 is hereby VACATED and RESCHEDULED for 10:00 a.m. May 30, 2019 in Courtroom 21. Signed by Judge Randolph D. Moss on 5/28/2019. (lcrdm2, ) (Entered: 05/28/2019) | ||
| May 28, 2019 | Set/Reset Hearings: The Motion Hearing set for 5/28/2019 is VACATED and RESCHEDULED for 5/30/2019, at 10:00 AM, in Courtroom 21, before Judge Randolph D. Moss. (kt) (Entered: 05/28/2019) | ||
| 16 | May 29, 2019 | View | WAIVER OF SERVICE by NILAB RAHYAR TOLTON, ANDREA MAZINGO, JANE DOES 1-4. JONES DAY waiver sent on 5/28/2019, answer due 7/27/2019. (Marcuse, Deborah) (Entered: 05/29/2019) |
| May 30, 2019 | Minute Entry for proceedings held before Judge Randolph D. Moss: Motion Hearing held on 5/30/2019 re: 12 MOTION Compel Compliance with Federal Rule 10(a) filed by JONES DAY. Order forthcoming. (Court Reporter: Jeff Hook.) (kt) (Entered: 05/30/2019) | ||
| May 30, 2019 | MINUTE ORDER: For the reasons stated on the record, it is herebyORDERED that Defendant may disclose the identities of the Jane Doe Plaintiffs for the sole purpose of investigating the allegations contained in the Complaint and for preparing an answer or dispositive motion in response. In all other respects, the Court's April 9, 2019 Minute Order remains in place pending further order of the Court. It is further ORDERED that Plaintiffs shall provide additional evidence, if any, in support of pseudonymity by filing supplemental declarations for the two Jane Does currently in the United States on or before June 12, 2019, and for the two Jane Does travelling abroad on or before June 19, 2019. Defendant may file a response on or before June 26, 2019; and It is further ORDERED that the parties shall meet and confer and submit a joint status report, on or before June 19, 2019, proposing a schedule for filing an amended complaint, if any. Signed by Judge Randolph D. Moss on 5/30/2019. (lcrdm2, ) (Entered: 05/30/2019) | ||
| May 30, 2019 | Set/Reset Deadlines: Plaintiffs shall provide additional evidence, if any, in support of pseudonymity by filing supplemental declarations for the two Jane Does currently in the United States on or before June 12, 2019, and for the two Jane Does travelling abroad on or before June 19, 2019. Defendant may file a response on or before June 26, 2019. Joint Status Report due by 6/19/2019. (dot) (Entered: 05/31/2019) | ||
| 17 | May 31, 2019 | Request | TRANSCRIPT OF MOTION HEARING before Judge Randolph D. Moss held on May 30, 2019. Page Numbers: 1 - 57. Date of Issuance: May 31, 2019. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced ab ove. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 6/21/2019. Redacted Transcript Deadline set for 7/1/2019. Release of Transcript Restriction set for 8/29/2019.(Hook, Jeff) (Entered: 05/31/2019) |
| 18 | Jun 9, 2019 | View | NOTICE Second Notice of Filing of Consent to Join Forms by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON (Attachments: # 1 Exhibit A)(Marcuse, Deborah) (Entered: 06/09/2019) |
| 19 | Jun 12, 2019 | View | Consent MOTION to Modify Minute Order by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON (Attachments: # 1 Text of Proposed Order to Modify Minute Order)(Marcuse, Deborah) (Entered: 06/12/2019) |
| Jun 12, 2019 | MINUTE ORDER: In light of Plaintiffs' consent motion for modification of minute order, it is hereby ORDERED that the following schedule shall govern: Plaintiffs shall file an Amended Complaint on or before June 24, 2019, in which Jane Doe Plaintiffs who intend to proceed under their own names shall supplement their allegations accordingly; Jane Doe 4 shall file a renewed motion to proceed under pseudonym, along with further evidence, if any, in support of pseudonymity on or before June 17, 2019; Defendant shall file any opposition on or before June 27, 2019, and any Plaintiffs shall file reply on or before July 3, 2019; and the parties shall meet and confer and submit a joint status report on or before June 26, 2019. Signed by Judge Randolph D. Moss on 6/12/2019. (lcrdm2, ) (Entered: 06/12/2019) | ||
| Jun 12, 2019 | Set/Reset Deadlines: Plaintiffs' Amended Complaint due by 6/24/2019. Jane Doe 4 Renewed Motion to proceed under pseudonym due by 6/17/2019. Defendant shall file any opposition due by 6/27/2019. Plaintiffs shall file Reply by 7/3/2019. Parties Meet & Confer Statement due by 6/26/2019. (dot) (Entered: 06/12/2019) | ||
| 20 | Jun 17, 2019 | View | Second MOTION to Proceed Under Pseudonym by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON (Attachments: # 1 Memorandum in Support (Redacted), # 2 Declaration of Deborah Marcuse, # 3 Text of Proposed Order)(Marcuse, Deborah) (Entered: 06/17/2019) |
| 21 | Jun 17, 2019 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Memorandum in Support of Motion to Seal, # 2 Declaration of Deborah Marcuse, # 3 Exhibit A (Sealed Declaration), # 4 Exhibit B (Sealed Unredacted Memorandum of Law), # 5 Text of Proposed Order)(Marcuse, Deborah) (Entered: 06/17/2019) |
| Jun 18, 2019 | MINUTE ORDER: Upon consideration of the unopposed motion for leave to file document under seal, Dkt. 21, it is hereby ORDERED that the motion is GRANTED. The sealed declaration and unredacted memorandum in support of the second motion to proceed under pseudonym are hereby DEEMED FILED. Signed by Judge Randolph D. Moss on 6/18/2019. (lcrdm2, ) (Entered: 06/18/2019) | ||
| 22 | Jun 18, 2019 | Request | MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Russell L. Kornblith, :Firm- Sanford Heisler Sharp, LLP, :Address- 1350 Avenue of the Americas, 31st Floor. Phone No. - (646) 402-5646. Fax No. - (646) 402-5651 Filing fee $ 100, receipt number 0090-6197215. Fee Status: Fee Paid. by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON (Attachments: # 1 Declaration of Russell L. Kornblith, # 2 Text of Proposed Order)(Marcuse, Deborah) (Entered: 06/18/2019) |
| 23 | Jun 18, 2019 | Request | SEALED DOCUMENT (Declaration) filed by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON. re 20 Second MOTION to Proceed Under Pseudonym filed by ANDREA MAZINGO, NILAB RAHYAR TOLTON, JANE DOES 1-4. (This document is SEALED and only available to authorized persons.)(ztd) (Entered: 06/19/2019) |
| 24 | Jun 18, 2019 | Request | SEALED DOCUMENT (Memorandum) filed by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON. re 20 Second MOTION to Proceed Under Pseudonym filed by ANDREA MAZINGO, NILAB RAHYAR TOLTON, JANE DOES 1-4. (This document is SEALED and only available to authorized persons.)(ztd) (Main Document 24 replaced on 6/20/2019) (znmw). (Entered: 06/19/2019) |
| Jun 20, 2019 | MINUTE ORDER: Upon consideration of the Motion for Leave to Appear Pro Hac Vice, Dkt. 22, it is hereby ORDERED that the motion is GRANTED. Russell L. Kornblith may appear pro hac vice in this matter. Signed by Judge Randolph D. Moss on 6/20/2019. (lcrdm2, ) (Entered: 06/20/2019) | ||
| 25 | Jun 20, 2019 | View | NOTICE Third Notice of Filing of Consent to Join Form by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON (Attachments: # 1 Notice and Consent)(Marcuse, Deborah) (Entered: 06/20/2019) |
| 26 | Jun 24, 2019 | View | ENTERED IN ERROR.....AMENDED COMPLAINT against JONES DAY with Jury Demand filed by NILAB RAHYAR TOLTON, ANDREA MAZINGO, JANE DOES 1-4. (Attachments: # 1 Exhibit Redline Comparison to Original Complaint)(Marcuse, Deborah); Modified on 6/25/2019 (tth). (Entered: 06/24/2019) |
| 27 | Jun 24, 2019 | View | AMENDED COMPLAINT against JONES DAY with Jury Demand filed by NILAB RAHYAR TOLTON, ANDREA MAZINGO, JANE DOES 1-4. (Attachments: # 1 Exhibit Redline Comparison to Original Complaint)(Marcuse, Deborah); Modified text at the request of counsel on 6/25/2019 (tth). (Entered: 06/24/2019) |
| Jun 25, 2019 | NOTICE OF CORRECTED DOCKET ENTRY: re 26 Amended Complaint, was entered in error at the request of counsel. Said pleading was refiled as document 27 . (tth) (Entered: 06/25/2019) | ||
| 28 | Jun 26, 2019 | View | Joint STATUS REPORT by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON. (Marcuse, Deborah) (Entered: 06/26/2019) |
| 29 | Jun 27, 2019 | View | Memorandum in opposition to re 20 Second MOTION to Proceed Under Pseudonym filed by JONES DAY. (Attachments: # 1 Proposed Order)(Powers, MaryEllen) (Entered: 06/27/2019) |
| 30 | Jun 27, 2019 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Unredacted Memorandum in Opposition to Motion to Proceed under Pseudonym, # 2 Exhibit A - Orr Declaration, # 3 Exhibit B - Shumaker Declaration, # 4 Proposed Order)(Powers, MaryEllen) (Entered: 06/27/2019) |
| Jul 2, 2019 | MINUTE ORDER: Upon consideration of the unopposed motion for leave to file document under seal, Dkt. 30, it is hereby ORDERED that the motion is GRANTED. The sealed declarations and unredacted memorandum in support of Defendant's opposition are hereby DEEMED FILED. Signed by Judge Randolph D. Moss on 7/2/2019. (lcrdm2, ) (Entered: 07/02/2019) | ||
| Jul 2, 2019 | MINUTE ORDER: In light of the parties' joint status report, Dkt, 28, it is hereby ORDERED that the following schedule shall govern class certification briefing: Plaintiffs shall file their motion for class certification on or before 90 days from the date that Jones Day files an answer to Plaintiffs' amended complaint; Defendant shall file an opposition on or before 30 days from the date of Plaintiffs' motion; and Plaintiffs shall file a reply on or before 14 days from Defendant's opposition. Should either party seek to extend this schedule due to any pre-class certification discovery dispute, the parties are directed to file a motion at that time. Signed by Judge Randolph D. Moss on 7/2/2019. (lcrdm2, ) (Entered: 07/02/2019) | ||
| 31 | Jul 2, 2019 | Request | SEALED DOCUMENT filed by JONES DAY. re 1 MOTION to Proceed Under Pseudonym MOTION for Order filed by ANDREA MAZINGO, NILAB RAHYAR TOLTON, JANE DOES 1-4. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Declaration Kevyn D. Orr, # 2 Declaration Michael R. Shumaker)(ztd) (Entered: 07/03/2019) |
| 32 | Jul 3, 2019 | View | REPLY to opposition to motion re 20 Second MOTION to Proceed Under Pseudonym (Redacted) filed by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON. (Kornblith, Russell) (Entered: 07/03/2019) |
| 33 | Jul 3, 2019 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Memorandum in Support of Motion to Seal, # 2 Declaration of Russell Kornblith, # 3 Exhibit 1 (Sealed Declaration), # 4 Exhibit A to Sealed Declaration, # 5 Exhibit 2 (Sealed Unredacted Memorandum of Law), # 6 Text of Proposed Order)(Kornblith, Russell) (Entered: 07/03/2019) |
| 34 | Jul 8, 2019 | View | NOTICE of Appearance by Katie Marie Mueting on behalf of All Plaintiffs (Mueting, Katie) (Main Document 34 replaced on 7/9/2019) (ztd). (Entered: 07/08/2019) |
| Jul 10, 2019 | MINUTE ORDER: Upon consideration of the unopposed motion for leave to file document under seal, Dkt. 33, it is hereby ORDERED that the motion is GRANTED. The unredacted memorandum in support of Plaintiff's reply, sealed declaration, and corresponding exhibits are hereby DEEMED FILED. Signed by Judge Randolph D. Moss on 7/10/2019. (lcrdm2, ) (Entered: 07/10/2019) | ||
| 35 | Jul 10, 2019 | Request | SEALED REPLY TO OPPOSITION filed by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON re 1 MOTION to Proceed Under Pseudonym MOTION for Order (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Declaration Russell Kornblith, # 2 Declaration # 3 Exhibit to Declaration)(ztd) Modified on 7/10/2019 to match public attachment title (kt). (Entered: 07/10/2019) |
| 36 | Jul 26, 2019 | View | ANSWER to 27 Amended Complaint, by JONES DAY.(Chase, Terri) (Entered: 07/26/2019) |
| 37 | Jul 29, 2019 | View | MOTION for Judgment on the Pleadings (Partial Judgment) by JONES DAY (Attachments: # 1 Text of Proposed Order)(Powers, MaryEllen) (Entered: 07/29/2019) |
| 38 | Aug 2, 2019 | View | Consent MOTION for Extension of Time to File Response/Reply as to 37 MOTION for Judgment on the Pleadings (Partial Judgment) by JANE DOES 1-4, ANDREA MAZINGO, NILAB RAHYAR TOLTON (Attachments: # 1 Text of Proposed Order)(Marcuse, Deborah) (Entered: 08/02/2019) |
| Aug 5, 2019 | MINUTE ORDER: Upon consideration of Plaintiffs' unopposed motion for extension of time, it is hereby ORDERED that the motion is GRANTED. Plaintiff shall file its opposition to Defendant's motion for partial judgment, Dkt. 37, on or before August 22, 2019, and Defendant shall file its reply on or before September 3, 2019. Signed by Judge Randolph D. Moss on 08/05/2019. (lcrdm2, ) (Entered: 08/05/2019) | ||
| Aug 5, 2019 | Set/Reset Deadlines: Plaintiff shall file its opposition to Defendant's motion for partial judgment, Dkt. 37, on or before 8/22/2019; Defendant shall file its reply on or before 9/3/2019. (kt) (Entered: 08/05/2019) | ||
| 39 | Aug 7, 2019 | Request | SEALED MEMORANDUM OPINION and ORDER denying the 20 Second MOTION to Proceed Under Pseudonym. (This document is SEALED and only available to authorized persons.)Signed by Judge Randolph D. Moss on 8/7/2019.(zkt) (Entered: 08/07/2019) |
| Aug 7, 2019 | MINUTE ORDER: In light of the Court's opinion, Dkt. 39, Plaintiffs are hereby ORDERED to file a second amended complaint disclosing the identity of Jane Doe 4 on or before August 12, 2019. Signed by Judge Randolph D. Moss on 08/07/2019. (lcrdm2, ) (Entered: 08/07/2019) | ||
| Aug 8, 2019 | Set/Reset Deadlines: Second Amended Complaint due by 8/12/2019. (kt) (Entered: 08/08/2019) | ||
| 40 | Aug 13, 2019 | View | AMENDED COMPLAINT against JONES DAY with Jury Demand filed by NILAB RAHYAR TOLTON, ANDREA MAZINGO, JANE DOES 1-4. (Attachments: # 1 Redline Comparison to Amended Complaint)(Marcuse, Deborah) (Entered: 08/13/2019) |
| 41 | Aug 16, 2019 | View | AMENDED COMPLAINT against JONES DAY with Jury Demand filed by NILAB RAHYAR TOLTON, ANDREA MAZINGO, JANE DOES 1-4. (Attachments: # 1 Exhibit Redline to Second Amended Complaint)(Marcuse, Deborah) (Entered: 08/16/2019) |
| 42 | Aug 20, 2019 | View | STRICKEN PURSUANT TO ORDER 50 . . . . . MOTION to Strike 41 Amended Complaint by JONES DAY (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C)(Powers, MaryEllen) Modified on 9/10/2019 (ztd). (Entered: 08/20/2019) |
| 43 | Aug 22, 2019 | View | Memorandum in opposition to re 37 MOTION for Judgment on the Pleadings (Partial Judgment) filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (Kornblith, Russell) (Entered: 08/22/2019) |
| 44 | Aug 27, 2019 | View | ANSWER to 40 Amended Complaint by JONES DAY.(Chase, Terri) (Entered: 08/27/2019) |
| 45 | Aug 29, 2019 | Request | MOTION for Extension of Time to Respond to the Third Amended Complaint by JONES DAY (Attachments: # 1 Text of Proposed Order)(Chase, Terri) Modified on 8/30/2019 (ztd). (Entered: 08/29/2019) |
| Aug 30, 2019 | MINUTE ORDER: Upon consideration of Defendant's motion for extension of time, Dkt. 45 , the motion is hereby GRANTED. The Court ORDERS that Defendant's time to respond to Plaintiff's third amended complaint, Dkt. 41, if a response is required, is hereby extended to 14 days after the Court rules on Defendant's motion to strike, Dkt. 42. Signed by Judge Randolph D. Moss on 08/30/2019. (lcrdm2, ) (Entered: 08/30/2019) | ||
| 46 | Aug 30, 2019 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Redacted Memorandum Opinion and Order, # 2 Exhibit Proposed Redactions, # 3 Text of Proposed Order)(Marcuse, Deborah) (Entered: 08/30/2019) |
| Sep 3, 2019 | MINUTE ORDER: On August 7, 2019, the Court denied Plaintiffs' second motion to proceed under pseudonym. Dkt. 39. Because the opinion discussed certain private information, the Court filed its opinion under seal and provided the parties with an opportunity to propose redactions before the Court filed a public version of the opinion. Subsequently, Plaintiffs filed an amended complaint omitting Doe 4 as a party to the litigation. See Dkt. 40. Plaintiffs have also now filed proposed redactions to the Court's opinion, and Defendant does not oppose Plaintiffs' request that the Court adopt the proposed redactions. Dkt. 46. Although those redactions are more extensive than the Court envisioned when it issued the opinion, the fact that Doe 4 is no longer a party to the litigation alters the balance between the public interest in judicial transparency and Doe 4's interest in privacy. In particular, many of the proposed redactions do not reveal detailed, personal information about Doe 4 but might reveal her identity. Because she has declined to participate in the litigation, the public interest in knowing her identity is substantially diminished. The Court will, accordingly, publish its opinion, Dkt. 39, with the redactions that Plaintiffs have proposed, Dkt. 46-1. Signed by Judge Randolph D. Moss on 09/03/2019. (lcrdm2, ) (Entered: 09/03/2019) | ||
| 47 | Sep 3, 2019 | View | REPLY to opposition to motion re 37 MOTION for Judgment on the Pleadings (Partial Judgment) filed by JONES DAY. (Powers, MaryEllen) (Entered: 09/03/2019) |
| 48 | Sep 3, 2019 | View | Memorandum in opposition to re 42 MOTION to Strike 41 Amended Complaint filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A, # 3 Exhibit B)(Marcuse, Deborah) (Entered: 09/03/2019) |
| 49 | Sep 4, 2019 | View | REPLY to opposition to motion re 42 MOTION to Strike 41 Amended Complaint filed by JONES DAY. (Powers, MaryEllen) (Entered: 09/04/2019) |
| 50 | Sep 6, 2019 | View | ORDER: It is hereby ORDERED that Defendant's motion to strike, Dkt. 42 , is GRANTED. The Court, however, will treat Plaintiffs' opposition to Defendant's motion to strike, Dkt. 48, as a motion for leave to file a third amended complaint. Accordingly, the Court further ORDERS that, if Defendant opposes that motion, Defendant shall file an opposition brief on or before September 16, 2019, and, if necessary, Plaintiffs shall file a reply on or before September 23, 2019. See document for details. Signed by Judge Randolph D. Moss on 09/06/2019. (lcrdm2, ) (Entered: 09/06/2019) |
| Sep 6, 2019 | Set/Reset Deadlines: Defendant's opposition brief, if any, is due on or before 9/16/201; If necessary, Plaintiffs' reply is due on or before 9/23/2019. (kt) (Entered: 09/06/2019) | ||
| 52 | Sep 6, 2019 | View | MOTION to Amend/Correct 41 Amended Complaint by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (ztd); (See docket entry no. 48 to view. Filed Pursuant to 50 Order) Modified text on 9/11/2019 (znmw). (Entered: 09/10/2019) |
| 51 | Sep 9, 2019 | View | Joint MOTION for Protective Order And Order Regarding Production Of Electronically-Stored Information (ESI) by JONES DAY (Attachments: # 1 Text of Proposed Order Regarding Confidentiality Of Discovery Material, # 2 Text of Proposed Order Regarding Production Of Electronically-Stored Information (ESI))(Chase, Terri). Added MOTION for Order on 9/10/2019 (ztd). (Entered: 09/09/2019) |
| 53 | Sep 11, 2019 | View | REDACTED MEMORANDUM AND OPINION: Denying Plaintiff's Second MOTION to Proceed Under Pseudonym, Dkt. 20, with redactions pursuant to the Court's September 3, 2019 Minute Order. Signed by Judge Randolph D. Moss on 09/11/2019. (lcrdm2, ) (Entered: 09/11/2019) |
| 54 | Sep 11, 2019 | View | STIPULATED PROTECTIVE ORDER: Upon consideration of the parties' joint motion for protective order, Dkt. 51 , it is hereby ORDERED that the motion is GRANTED. The parties shall comply with the terms of the stipulated protective order, which the Court adopts in full. See the attached document for further details. Signed by Judge Randolph D. Moss on 09/10/2019. (lcrdm2, ) Modified on 9/12/2019 to substitute "Minute Order" for document title, and to correct the date of the Judge's signature to match the signature date on the order (kt). (Entered: 09/11/2019) |
| 55 | Sep 16, 2019 | View | RESPONSE re 52 MOTION to Amend/Correct 41 Amended Complaint filed by JONES DAY. (Attachments: # 1 Text of Proposed Order Granting Plaintiffs' Motion for Leave to File Third Amended Complaint)(Chase, Terri) (Entered: 09/16/2019) |
| Sep 17, 2019 | MINUTE ORDER: As explained in its previous Order, Dkt. 50, the Court construed Plaintiffs' opposition to Defendant's motion to strike as a motion to leave to file a third amended complaint and ordered Defendant to file an opposition brief, if necessary. In response, Defendant has proposed, and Plaintiffs consented to, a "resolution that would streamline" the briefing on this issue. Dkt. 55. Upon consideration of that proposal, it is hereby ORDERED that the Plaintiffs' motion for leave to file a third amended complaint is GRANTED and Plaintiffs' Third Amended Complaint, DKt. 41, is hereby deemed filed. It is further ORDERED that the following schedule shall govern future proceedings in this matter: Defendant shall file an Answer to Plaintiffs' Third Amended Complaint, Dkt. 41, along with a supplemental Rule 12(c) memorandum of law addressing only the Third Amended Complaint's new allegations (as indicated by the red line) on or before October 8, 2019; Plaintiffs shall file an opposition, similarly limited to the new allegations, on or before October 22, 2019; and Defendant shall file its reply on or before October 29, 2019. Plaintiffs' class certification shall be filed on or before January 17, 2020 or 30 days after this Court's resolution of Defendant's 12(c) motion, whichever is later. Signed by Judge Randolph D. Moss on 09/17/2019. (lcrdm2, ) (Entered: 09/17/2019) | ||
| Sep 18, 2019 | Set/Reset Deadlines: Defendants' Answer and Supplemental Memorandum of Law are due by 10/8/2019; Plaintiffs' Opposition due by 10/22/2019; Defendants' Reply due by 10/29/2019; Plaintiffs' class certification due by 1/17/2020 or 30 days after this Court's resolution of Defendant's 12(c) motion, whichever is later. (kt) (Entered: 09/18/2019) | ||
| 56 | Sep 26, 2019 | Request | MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Rebekah B. Kcehowski, :Firm- Jones Day, :Address- 500 Grant Street, Suite 4500, Pittsburgh, PA 15219-2514. Phone No. - (412) 394-7935. Fax No. - (412) 394-7959 Filing fee $ 100, receipt number 0090-6401058. Fee Status: Fee Paid. by JONES DAY (Attachments: # 1 Declaration, # 2 Text of Proposed Order)(Powers, MaryEllen) (Entered: 09/26/2019) |
| Sep 26, 2019 | MINUTE ORDER: Upon consideration of Defendant's Motion for Leave to Appear Pro Hac Vice, Dkt. 56, it is hereby ORDERED that the motion is GRANTED. Rebekah B. Kcehowski is hereby granted leave to appear pro hac vice in this case. Signed by Judge Randolph D. Moss on 09/26/19. (lcrdm2, ) (Entered: 09/26/2019) | ||
| 57 | Oct 8, 2019 | View | ANSWER to 41 Amended Complaint by JONES DAY.(Chase, Terri) (Entered: 10/08/2019) |
| 58 | Oct 8, 2019 | View | SUPPLEMENTAL MEMORANDUM to re 37 MOTION for Judgment on the Pleadings (Partial Judgment) filed by JONES DAY. (Powers, MaryEllen) (Entered: 10/08/2019) |
| 59 | Oct 21, 2019 | Request | Consent MOTION for Extension of Time to File Response/Reply as to 37 MOTION for Judgment on the Pleadings (Partial Judgment) by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Attachments: # 1 Text of Proposed Order)(Marcuse, Deborah) (Entered: 10/21/2019) |
| Oct 21, 2019 | MINUTE ORDER: Upon consideration of Plaintiffs' unopposed motion for extension of time, Dkt. 59 , it is hereby ORDERED that the motion is GRANTED. Plaintiffs shall file an opposition on or before October 24, 2019; and Defendant shall file its reply on or before October 31, 2019. Signed by Judge Randolph D. Moss on 10/21/2019. (lcrdm2, ) (Entered: 10/21/2019) | ||
| 60 | Oct 24, 2019 | View | SUPPLEMENTAL MEMORANDUM re 37 MOTION for Judgment on the Pleadings (Partial Judgment) filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (Attachments: # 1 Text of Proposed Order)(Marcuse, Deborah) Modified event title on 10/25/2019 (znmw). (Entered: 10/24/2019) |
| 61 | Oct 31, 2019 | View | SUPPLEMENTAL MEMORANDUM to re 37 MOTION for Judgment on the Pleadings (Partial Judgment) (Reply) filed by JONES DAY. (Powers, MaryEllen) (Entered: 10/31/2019) |
| Nov 4, 2019 | NOTICE of Hearing: A Status Conference re: Discovery Dispute is set for 11/7/2019, at 10:00 AM, in Courtroom 21, before Judge Randolph D. Moss. (kt) (Entered: 11/04/2019) | ||
| Nov 6, 2019 | MINUTE ORDER: In light of the discovery dispute status conference scheduled for November 7, 2019, it is hereby ORDERED that the parties shall provide the Court with any materials that they wish the Court to consider by 4:00 p.m. today, November 6, 2019. Signed by Judge Randolph D. Moss on 11/6/19. (lcrdm1) (Entered: 11/06/2019) | ||
| 62 | Nov 6, 2019 | View | NOTICE of Appearance by Paul Blankenstein on behalf of All Plaintiffs (Blankenstein, Paul) (Main Document 62 replaced on 11/7/2019) (ztd). (Entered: 11/06/2019) |
| Nov 6, 2019 | NOTICE OF ERROR re 62 Notice of Appearance; emailed to pblankenstein@gibsondunn.com, cc'd 20 associated attorneys -- The PDF file you docketed contained errors: 1. Your address needs to be updated through Pacer. (ztd, ) (Entered: 11/06/2019) | ||
| Nov 7, 2019 | Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference re: Discovery Dispute held on 11/7/2019. Issues addressed. Class certification discovery will be postponed. Order forthcoming as to the 37 Motion for Judgment on the Pleadings (Partial Judgment). (Court Reporter: Jeff Hook.) (kt) (Entered: 11/07/2019) | ||
| 63 | Nov 11, 2019 | View | STIPULATION by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (Attachments: # 1 Text of Proposed Order)(Mueting, Katie) (Entered: 11/11/2019) |
| Nov 12, 2019 | MINUTE ORDER: In light of the parties' joint stipulation to permit access to the sealed portion of the November 7, 2019 transcript, it is hereby ORDERED that access to the transcript of the sealed proceedings is GRANTED for the sole purpose of providing a copy of the transcript to counsel. It is further ORDERED that the U.S. District Court Reporter is authorized to provide a complete copy of the November 7, 2019 hearing transcript, including the sealed portion, to counsel for both parties. It is further ORDERED that the Court's sealing of that transcript shall otherwise remain in effect. Signed by Judge Randolph D. Moss on 11/12/19. (lcrdm1) (Entered: 11/12/2019) | ||
| 64 | Nov 13, 2019 | Request | TRANSCRIPT OF STATUS CONFRENCE before Judge Randolph D. Moss held on November 7, 2019. Page Numbers: 1 - 64. Date of Issuance: November 13, 2019. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter re ferenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 12/4/2019. Redacted Transcript Deadline set for 12/14/2019. Release of Transcript Restriction set for 2/11/2020.(Hook, Jeff) (Entered: 11/13/2019) |
| Nov 21, 2019 | MINUTE ORDER: In light of the pending motion for partial judgment on the pleadings, Dkt. 37 , it is hereby ORDERED that the parties shall appear for oral argument on the motion on Monday, December 9, 2019 at 10:00 a.m. Signed by Judge Randolph D. Moss on 11/21/19. (lcrdm1) (Entered: 11/21/2019) | ||
| Nov 25, 2019 | MINUTE ORDER: It is hereby ORDERED that oral argument previously scheduled for December 9, 2019 is hereby VACATED and RESCHEDULED for December 16, 2019 at 10:00 a.m. Signed by Judge Randolph D. Moss on 11/25/19. (lcrdm1) (Entered: 11/25/2019) | ||
| 65 | Dec 4, 2019 | View | MOTION to Certify Class Conditionally Under the Equal Pay Act by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O)(Mueting, Katie) (Entered: 12/04/2019) |
| 66 | Dec 4, 2019 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Unredacted Memorandum Supporting Conditional Certification, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit J, # 9 Exhibit K, # 10 Exhibit L, # 11 Exhibit M, # 12 Exhibit N, # 13 Exhibit O, # 14 Text of Proposed Order)(Mueting, Katie) (Entered: 12/04/2019) |
| Dec 5, 2019 | MINUTE ORDER: Upon consideration of Plaintiffs' motion for leave to file under seal, Dkt. 66 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Plaintiffs may file the referenced documents provisionally under seal in unredacted form. It is further ORDERED that, if Defendant wishes to maintain certain of these documents under seal, it shall file a motion to seal on or before December 16, 2019. If Defendant does not file a motion to seal by that date, Plaintiffs shall promptly refile the materials contained in Dkt. 66 on the public docket. Signed by Judge Randolph D. Moss on 12/5/19. (lcrdm1) (Entered: 12/05/2019) | ||
| 67 | Dec 5, 2019 | Request | SEALED DOCUMENT filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. re 65 MOTION to Certify Class Conditionally Under the Equal Pay Act filed by SAIRA DRAPER, ANDREA MAZINGO, NILAB RAHYAR TOLTON, KATRINA HENDERSON, JACLYN STAHL, MEREDITH WILLIAMS. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit A-O)(ztd) (Entered: 12/06/2019) |
| 68 | Dec 6, 2019 | View | MOTION for Sanctions (Rule 11) by JONES DAY (Attachments: # 1 Declaration of Terri L. Chase in Support of Defendant's Motion for Rule 11 Sanctions, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18)(Powers, MaryEllen) (Entered: 12/06/2019) |
| 69 | Dec 6, 2019 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Memorandum in Support of Defendant's Motion for Rule 11 Sanctions, # 2 Declaration of Terri L Chase in Support of Defendant's Motion for Rule 11 Sanctions, # 3 Exhibit 1, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 15, # 10 Exhibit 17, # 11 Text of Proposed Order)(Powers, MaryEllen) (Entered: 12/06/2019) |
| 70 | Dec 6, 2019 | Request | NOTICE of Proposed Order Granting Motion for Sanctions by JONES DAY re 68 MOTION for Sanctions (Rule 11) (Powers, MaryEllen) (Entered: 12/06/2019) |
| 71 | Dec 6, 2019 | Request | NOTICE of Appearance by Jacob M. Roth on behalf of JONES DAY (Roth, Jacob) (Entered: 12/06/2019) |
| Dec 6, 2019 | NOTICE OF ERROR re 71 Notice of Appearance; emailed to yroth@jonesday.com, cc'd 21 associated attorneys -- The PDF file you docketed contained errors: 1. Counsel must contact Attorney Admissions at: (202) 354-3110 regarding status. (ztd, ) (Entered: 12/06/2019) | ||
| Dec 6, 2019 | MINUTE ORDER: Upon consideration of Defendant's motion to file provisionally under seal, Dkt. 69 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Defendant may file the referenced documents provisionally under seal in unredacted form. It is further ORDERED that, if either Plaintiffs or Defendant wishes to maintain certain of these documents or their contents under seal, they shall file a motion to seal on or before December 17, 2019. If neither Plaintiffs nor Defendant files a motion to seal by that date, Defendant shall promptly refile the materials contained in Dkt. 69 on the public docket. Signed by Judge Randolph D. Moss on 12/6/19. (lcrdm1) (Entered: 12/06/2019) | ||
| 73 | Dec 6, 2019 | Request | SEALED MOTION filed by JONES DAY. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Declaration, # 2 Exhibit 1, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 15, # 9 Exhibit 17)(ztd) (Entered: 12/09/2019) |
| 72 | Dec 9, 2019 | Request | MOTION for Extension of Time to File Response/Reply as to 65 MOTION to Certify Class Conditionally Under the Equal Pay Act by JONES DAY (Attachments: # 1 Text of Proposed Order)(Powers, MaryEllen) (Entered: 12/09/2019) |
| 74 | Dec 12, 2019 | View | Consent MOTION for Extension of Time to File Response/Reply as to 65 MOTION to Certify Class Conditionally Under the Equal Pay Act by JONES DAY (Attachments: # 1 Text of Proposed Order)(Powers, MaryEllen) (Entered: 12/12/2019) |
| 75 | Dec 12, 2019 | View | Consent MOTION for Extension of Time to File Response/Reply as to 68 MOTION for Sanctions (Rule 11) by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Attachments: # 1 Text of Proposed Order)(Marcuse, Deborah) (Entered: 12/12/2019) |
| Dec 12, 2019 | MINUTE ORDER: Upon consideration of Defendant's consent motion for extension of time, Dkt. 74 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Defendant shall respond to Plaintiffs' certification motion on or before January 8, 2020. It is further ORDERED that any EPA claims held by members of the putative collective shall be equitably tolled until that date. Signed by Judge Randolph D. Moss on 12/12/19. (lcrdm1) (Entered: 12/12/2019) | ||
| Dec 13, 2019 | MINUTE ORDER: Upon consideration of Plaintiffs' consent motion for extension of time, Dkt. 75 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Plaintiffs shall file their opposition to Defendant's motion for sanctions on or before January 7, 2020 and Defendant shall file its reply in support of its motion for sanctions on or before January 24, 2020. Signed by Judge Randolph D. Moss on 12/13/19. (lcrdm1) (Entered: 12/13/2019) | ||
| Dec 16, 2019 | Minute Entry for proceedings held before Judge Randolph D. Moss: Motion Hearing held on 12/16/2019 re: 37 MOTION for Judgment on the Pleadings (Partial Judgment) filed by JONES DAY. MATTER TAKEN UNDER ADVISEMENT. (Court Reporter: Lisa Edwards.) (kt) (Entered: 12/16/2019) | ||
| 76 | Dec 16, 2019 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 1 - Information To Be Sealed, # 2 Exhibit 2 - Plaintiffs' Memorandum (Redacted), # 3 Exhibit 3 - Plaintiffs' Ex. A (Redacted), # 4 Exhibit 4 - Plaintiffs' Ex. C (Redacted), # 5 Exhibit 5 - Plaintiffs' Ex. D (Redacted), # 6 Exhibit 6 - Plaintiffs' Ex. E (Redacted), # 7 Exhibit 7 - Plaintiffs' Ex. F (Redacted), # 8 Exhibit 8 - Plaintiffs' Ex. K (Redacted), # 9 Exhibit 9 - Plaintiffs' Ex. L (Redacted), # 10 Exhibit 10 - Plaintiffs' Ex. M (Redacted), # 11 Exhibit 11 - Plaintiffs' Ex. N (Redacted), # 12 Text of Proposed Order)(Roth, Jacob) (Entered: 12/16/2019) |
| 77 | Dec 17, 2019 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Text of Proposed Order)(Powers, MaryEllen) (Entered: 12/17/2019) |
| 78 | Dec 17, 2019 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Text of Proposed Order)(Marcuse, Deborah) (Entered: 12/17/2019) |
| Dec 18, 2019 | MINUTE ORDER: Upon consideration of Defendant's motions for leave to file documents under seal, Dkt. 76 & Dkt. 77 , and Plaintiffs' motion for leave to file document under seal, Dkt. 78 , it is hereby ORDERED that the parties shall confer and, on or before January 3, 2020, shall jointly file agreed-upon proposed redactions for each exhibit for which redactions are sought by either party. If any disputes remain pertaining to certain exhibits following the parties' conferral, each party shall also file, at the same time, separate copies of each disputed exhibit, including the proposed redactions that the party deems appropriate along with a corresponding explanation of the basis for the parties' dispute regarding each redaction upon which the parties cannot agree. The Court notes that "the starting point in considering a motion to seal court records is a 'strong presumption in favor or public access to judicial proceedings.'" EEOC v. National Children's Center, Inc., 98 F.3d 1406, 1409 (D.C. Cir. 1996) (quoting Johnson v. Greater Southeast Cmty. Hosp. Corp., 951 F.2d 1268, 1277 (D.C. Cir. 1991)). Signed by Judge Randolph D. Moss on 12/18/19. (lcrdm1) Modified on 12/19/2019 to correct date/year (kt). (Entered: 12/18/2019) | ||
| 79 | Dec 20, 2019 | Request | TRANSCRIPT OF MOTION HEARING before Judge Randolph D. Moss held on December 16, 2019; Page Numbers: 1-108. Date of Issuance: December 20, 2019. Court Reporter/Transcriber Lisa Edwards. Telephone number (202) 354-3269. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court repo rter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 1/10/2020. Redacted Transcript Deadline set for 1/20/2020. Release of Transcript Restriction set for 3/19/2020.(Edwards, Lisa) (Entered: 12/20/2019) |
| 80 | Dec 23, 2019 | Request | Consent MOTION for Extension of Time to File Response/Reply as to 65 MOTION to Certify Class Conditionally Under the Equal Pay Act by JONES DAY (Attachments: # 1 Text of Proposed Order)(Roth, Jacob) (Entered: 12/23/2019) |
| Dec 23, 2019 | MINUTE ORDER: Upon consideration of the parties' consent motion for extension of time, Dkt. 80 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Defendant shall respond to Plaintiffs' conditional certification motion on or before January 22, 2020. It is further ORDERED that any EPA claims held by members of the putative collective shall be tolled until that date. Signed by Judge Randolph D. Moss on 12/23/19. (lcrdm1) (Entered: 12/23/2019) | ||
| 81 | Dec 23, 2019 | Request | Memorandum in opposition to re 72 MOTION for Extension of Time to File Response/Reply as to 65 MOTION to Certify Class Conditionally Under the Equal Pay Act filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (Attachments: # 1 Exhibit A, # 2 Text of Proposed Order)(Marcuse, Deborah) (Entered: 12/23/2019) |
| 82 | Dec 24, 2019 | Request | REPLY to opposition to motion re 72 MOTION for Extension of Time to File Response/Reply as to 65 MOTION to Certify Class Conditionally Under the Equal Pay Act filed by JONES DAY. (Roth, Jacob) (Entered: 12/24/2019) |
| Dec 27, 2019 | MINUTE ORDER: Upon consideration of Defendant's motion for extension of time to file a response, Dkt. 72 , Plaintiffs' memorandum in opposition, Dkt. 81 , and Defendant's reply, Dkt. 82 , it is hereby ORDERED that Defendant's motion is GRANTED. It is further ORDERED that Defendant shall respond to Plaintiffs' motion for conditional certification of an Equal Pay Act collective action and authorization of notice, Dkt. 65 , within 30 days of the Court's ruling on Defendant's pending Rule 12(c) motion, Dkt. 37 . It is further ORDERED that equitable tolling of the EPA claims of putative members of the collective, which began on December 18, 2019, see Minute Order (Dec. 12, 2019) (granting consent motion for three week extension from December 18, 2019 until January 8, 2020, Dkt. 74 , with equitable tolling), shall continue until 30 days after the Court's ruling on Defendant's pending Rule 12(c) motion. It is further ORDERED that, should Plaintiffs wish to amend their motion for conditional certification, Dkt. 65 , they shall seek the Court's leave to amend within one week of the issuance of Court's opinion on the motion for judgment on the pleadings. Signed by Judge Randolph D. Moss on 12/27/19. (lcrdm1) (Entered: 12/27/2019) | ||
| 83 | Jan 3, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Exhibit 1, # 2 Exhibit Exhibit 2, # 3 Exhibit Exhibit 3, # 4 Text of Proposed Order Proposed Order)(Chase, Terri) (Entered: 01/03/2020) |
| 84 | Jan 3, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Sealed Memo of Law, # 2 Exhibit Sealed Ex. C, # 3 Exhibit Sealed Ex. D, # 4 Exhibit Sealed Ex. E, # 5 Exhibit Sealed Ex. F, # 6 Exhibit Sealed Ex. L, # 7 Exhibit Sealed Ex. M, # 8 Exhibit Sealed Ex. N)(Marcuse, Deborah) (Entered: 01/03/2020) |
| 85 | Jan 3, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Sealed Memo of Law, # 2 Exhibit Sealed Ex. 3, # 3 Exhibit Sealed Ex. 4, # 4 Exhibit Sealed Ex. 5, # 5 Exhibit Sealed Ex. 6, # 6 Exhibit Sealed Ex. 15)(Marcuse, Deborah) (Entered: 01/03/2020) |
| 86 | Jan 3, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Sealed Ex. A, # 2 Exhibit Sealed Ex. 7, # 3 Exhibit Sealed Ex. K, # 4 Text of Proposed Order Sealed Proposed Order Denying Defendant's Motion to Seal, # 5 Text of Proposed Order Sealed Proposed Order Granting Plaintiffs' Sealed Motion to File Under Seal)(Marcuse, Deborah) (Entered: 01/03/2020) |
| 87 | Jan 7, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Declaration of Russell L. Kornblith, # 2 Exhibit Unredacted Memorandum in Opposition, # 3 Exhibit A, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit F, # 7 Exhibit I, # 8 Exhibit J, # 9 Exhibit L, # 10 Exhibit M, # 11 Exhibit N, # 12 Exhibit O, # 13 Exhibit P, # 14 Text of Proposed Order)(Kornblith, Russell) (Entered: 01/07/2020) |
| 88 | Jan 7, 2020 | View | Memorandum in opposition to re 68 MOTION for Sanctions (Rule 11) filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (Attachments: # 1 Declaration of Russell L. Kornblith, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Exhibit P, # 18 Text of Proposed Order)(Kornblith, Russell) (Entered: 01/07/2020) |
| Jan 9, 2020 | MINUTE ORDER: Upon consideration of Plaintiffs' motion to file provisionally under seal, Dkt. 87 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Plaintiffs may file the referenced documents provisionally under seal in unredacted form. It is further ORDERED that, if Defendant wishes to maintain certain of these documents or their contents under seal, it shall file a motion to seal on or before January 15, 2020. If Defendant does not file a motion to seal by that date, Plaintiffs shall promptly refile the materials contained in Dkt. 87 on the public docket. Signed by Judge Randolph D. Moss on 1/9/20. (lcrdm1) (Entered: 01/09/2020) | ||
| 89 | Jan 9, 2020 | Request | SEALED ORDER: Upon consideration of the parties' joint motions for leave to file under seal Dkt. 84 & Dkt. 85, it is hereby ORDERED that those motions are GRANTED; It is further ORDERED, that the parties shall file on the public docket the supporting exhibits to those motions, with the redactions agreed upon by the parties. Upon consideration of Defendant's motion to file under seal, Dkt. 83, and Plaintiffs' motion to file under seal, Dkt. 86, it is hereby ORDERED that those motions are GRANTED in part and DENIED in part. (See Order for further details.) (This document is SEALED and only available to authorized persons; copies were mailed to counsel of record.)Signed by Judge Randolph D. Moss on 1/9/2020.(zkt) (Entered: 01/09/2020) |
| 90 | Jan 9, 2020 | Request | SEALED OPPOSITION filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS re 68 MOTION for Sanctions (Rule 11) (Attachments: # 1 Exhibit A, # 2 Exhibit C, # 3 Exhibit D, # 4 Exhibit F, # 5 Exhibit I, # 6 Exhibit J, # 7 Exhibit L, # 8 Exhibit M, # 9 Exhibit N, # 10 Exhibit O, # 11 Exhibit P)(ztd) (Entered: 01/14/2020) |
| 91 | Jan 9, 2020 | Request | SEALED DOCUMENT filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. re 65 MOTION to Certify Class Conditionally Under the Equal Pay Act filed by SAIRA DRAPER, ANDREA MAZINGO, NILAB RAHYAR TOLTON, KATRINA HENDERSON, JACLYN STAHL, MEREDITH WILLIAMS. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit C, # 2 Exhibit D, # 3 Exhibit E, # 4 Exhibit F, # 5 Exhibit L, # 6 Exhibit M, # 7 Exhibit N)(ztd) (Entered: 01/14/2020) |
| 92 | Jan 15, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Sealed Memo of Law, # 2 Exhibit A, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit F, # 6 Exhibit I, # 7 Exhibit J, # 8 Text of Proposed Order)(Chase, Terri) (Entered: 01/15/2020) |
| 93 | Jan 16, 2020 | View | MOTION for Sanctions (REDACTED PER COURT'S ORDER - DKT. 89) by JONES DAY (Attachments: # 1 Declaration of Terri L. Chase in Support of Defendants Motion for Rule 11 Sanctions, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3 (REDACTED), # 5 Exhibit 4 (REDACTED), # 6 Exhibit 5 (REDACTED), # 7 Exhibit 6 (REDACTED), # 8 Exhibit 7 (REDACTED), # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15 (REDACTED), # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18)(Chase, Terri) (Entered: 01/16/2020) |
| 94 | Jan 16, 2020 | View | MOTION to Certify Class Conditionally Under the Equal Pay Act (REDACTED PER COURT'S ORDER -- DKT. 89) by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Text of Proposed Order)(Mueting, Katie) (Entered: 01/16/2020) |
| Jan 22, 2020 | MINUTE ORDER: Upon consideration of the parties' joint motion for leave to file under seal, Dkt. 92 , it is hereby ORDERED that the motion is GRANTED in part and DENIED in part. It is further ORDERED that the parties shall file on the public docket versions of the relevant documents with their proposed redactions, with the exception of Exhibits C and F. The parties shall file on the public docket versions of Exhibits C and F without their proposed redactions at the following lines: Exhibit C, 59:14; Exhibit F, 416:4. Signed by Judge Randolph D. Moss on 1/22/20. (lcrdm1) (Entered: 01/22/2020) | ||
| Jan 23, 2020 | MINUTE ORDER: The parties are hereby ORDERED to comply with the terms of the Court's revised standing order, which is available on the Court's website. Click for details. Signed by Judge Randolph D. Moss on 1/23/20. (lcrdm1) (Entered: 01/23/2020) | ||
| 95 | Jan 24, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 2, # 2 Exhibit 3, # 3 Exhibit 4, # 4 Exhibit 5, # 5 Exhibit 8, # 6 Text of Proposed Order)(Powers, MaryEllen) (Entered: 01/24/2020) |
| 96 | Jan 24, 2020 | View | REPLY to opposition to motion re 68 MOTION for Sanctions (Rule 11) filed by JONES DAY. (Attachments: # 1 Declaration Of Traci L. Lovitt In Support Of Defendants Motion For Rule 11 Sanctions, # 2 Declaration (Second) Of Terri L. Chase In Support Of Defendants Motion For Rule 11 Sanctions, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4, # 7 Exhibit 5, # 8 Exhibit 6, # 9 Exhibit 7, # 10 Exhibit 8, # 11 Exhibit 9, # 12 Exhibit 10, # 13 Exhibit 11)(Powers, MaryEllen) (Entered: 01/24/2020) |
| Jan 28, 2020 | MINUTE ORDER: Upon consideration of Defendant's motion to file provisionally under seal, Dkt. 95 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Defendant may file the referenced documents provisionally under seal in unredacted form. The Court notes, however, that the currently filed versions of Exhibits 2-5 contain redactions. It is further ORDERED that, if Defendant wishes to maintain certain of these documents or their contents under seal, it shall file a motion to seal on or before February 4, 2020. If Defendant does not file a motion to seal by that date, it shall promptly refile the materials contained in Dkt. 95 on the public docket. Signed by Judge Randolph D. Moss on 1/28/20. (lcrdm1) (Entered: 01/28/2020) | ||
| 98 | Jan 28, 2020 | Request | SEALED DOCUMENT (Exhibits) filed by JONES DAY. re 93 MOTION for Sanctions (REDACTED PER COURT'S ORDER - DKT. 89) filed by JONES DAY. (This document is SEALED and only available to authorized persons.)(ztd) (Entered: 01/30/2020) |
| 97 | Jan 29, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Sealed Joint Motion for Clarication, # 2 Text of Proposed Order Granting Joint Motion for Clarification, # 3 Text of Proposed Order)(Marcuse, Deborah) (Entered: 01/29/2020) |
| Jan 31, 2020 | MINUTE ORDER: Upon consideration of the parties' sealed motion for leave to file document under seal, Dkt. 97 , the motion is hereby DENIED. The Court acknowledges that there is an inconsistency between the Court's grant of the motion to seal "$200,000" at 58:23 of Exhibit 3 to Defendant's Motion for Rule 11 Sanctions, and its denial of the motion to seal "$200,000" at 59:14 of Exhibit C to Plaintiff's opposition to Defendant's Motion for Rule 11 Sanctions. Because an isolated salary offer made by another law firm to one individual several years ago is not sufficiently competitively sensitive to override the "strong presumption in favor of public access to judicial proceedings," the Court's order granting the motion to seal "$200,000" at 58:23 of Exhibit 3 to Defendant's Motion for Rule 11 Sanctions, is hereby VACATED, and it is hereby ORDERED that the parties shall file a copy of the exhibit in question without redacting the figure. Signed by Judge Randolph D. Moss on 1/31/20. (lcrdm1) (Entered: 01/31/2020) | ||
| 99 | Feb 3, 2020 | View | MOTION for Leave to File Sur-Reply by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Attachments: # 1 Exhibit A, # 2 Text of Proposed Order)(Kornblith, Russell) (Entered: 02/03/2020) |
| 100 | Feb 4, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 2, # 2 Exhibit 3, # 3 Exhibit 4, # 4 Exhibit 5, # 5 Exhibit 8, # 6 Exhibit 2A, # 7 Exhibit 3A, # 8 Exhibit 4A, # 9 Exhibit 5A, # 10 Text of Proposed Order)(Chase, Terri) (Entered: 02/04/2020) |
| 101 | Feb 4, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 2, # 2 Exhibit 3, # 3 Exhibit 4, # 4 Exhibit 5, # 5 Exhibit 8, # 6 Text of Proposed Order, # 7 Text of Proposed Order)(Marcuse, Deborah) (Entered: 02/04/2020) |
| 102 | Feb 7, 2020 | View | MOTION for Sanctions (REDACTED PER COURT'S ORDER - DKT. 89 AND 1/31/2020 MINUTE ORDER) by JONES DAY (Attachments: # 1 Declaration of Terri L. Chase in Support of Defendant's Motion for Rule 11 Sanctions, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3 (REDACTED), # 5 Exhibit 4 (REDACTED), # 6 Exhibit 5 (REDACTED), # 7 Exhibit 6 (REDACTED), # 8 Exhibit 7 (REDACTED), # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15 (REDACTED), # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18)(Chase, Terri) (Entered: 02/07/2020) |
| 103 | Feb 10, 2020 | View | Memorandum in opposition to re 99 MOTION for Leave to File Sur-Reply filed by JONES DAY. (Chase, Terri) (Entered: 02/10/2020) |
| 104 | Feb 12, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 1, # 2 Text of Proposed Order)(Chase, Terri) (Entered: 02/12/2020) |
| Feb 28, 2020 | MINUTE ORDER: Upon consideration of the Defendant's sealed motion for leave to file under seal, Dkt. 100 , and Plaintiffs sealed motion for leave to file under seal, Dkt. 101 , it is hereby ORDERED that the motions are GRANTED in part and DENIED in part. It is further ORDERED that Defendant shall file on the public record Exhibits 25 with the redactions featured in Exhibits 2A, 3A, 4A, and 5A to Dkt. 100 . It is further ORDERED that Defendant shall file Exhibit 8 with the redactions upon which the parties agree. Signed by Judge Randolph D. Moss on 2/28/20. (lcrdm1) (Entered: 02/28/2020) | ||
| 105 | Feb 28, 2020 | Request | SEALED DOCUMENT (Main Document is Exhibit 2) filed by JONES DAY. re 96 Reply to opposition to Motion,, filed by JONES DAY. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 2A, # 2 Exhibit 3, # 3 Exhibit 3A, # 4 Exhibit 4, # 5 Exhibit 4A, # 6 Exhibit 5, # 7 Exhibit 5A, # 8 Exhibit 8)(ztd) (Entered: 03/04/2020) |
| 106 | Feb 28, 2020 | Request | SEALED DOCUMENT (Exhibits; Main document Exhibit 2) filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 3, # 2 Exhibit 4, # 3 Exhibit 5, # 4 Exhibit 8)(ztd) (Entered: 03/04/2020) |
| 107 | Mar 4, 2020 | View | REDACTED DOCUMENT- Rule 11 Reply REDACTED per Court's 2/28/2020 Minute Order to 96 Reply to opposition to Motion,, by JONES DAY. (Attachments: # 1 Declaration of Traci L. Lovitt in Support of Defendant's Motion for Rule 11 Sanctions, # 2 Declaration (Second) of Terri L. Chase in Support of Defendant's Motion for Rule 11 Sanctions, # 3 Exhibit 1, # 4 Exhibit 2 (REDACTED), # 5 Exhibit 3 (REDACTED), # 6 Exhibit 4 (REDACTED), # 7 Exhibit 5 (REDACTED), # 8 Exhibit 6, # 9 Exhibit 7, # 10 Exhibit 8 (REDACTED), # 11 Exhibit 9, # 12 Exhibit 10, # 13 Exhibit 11)(Chase, Terri) (Entered: 03/04/2020) |
| 108 | Mar 5, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 2, # 2 Exhibit 3, # 3 Exhibit 4, # 4 Exhibit 5, # 5 Text of Proposed Order)(Chase, Terri) (Entered: 03/05/2020) |
| Mar 5, 2020 | MINUTE ORDER: Upon consideration of Defendant's sealed motion for leave to file under seal, Dkt. 108 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that the exhibits attached to that motion are hereby DEEMED FILED under seal. Signed by Judge Randolph D. Moss on 3/5/20. (lcrdm1) (Entered: 03/05/2020) | ||
| 109 | Mar 11, 2020 | Request | SEALED DOCUMENT (Revised Exhibits: Main document is exhibit 2) filed by JONES DAY. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 3, # 2 Exhibit 4, # 3 Exhibit 5)(ztd) (Entered: 03/11/2020) |
| 110 | May 19, 2020 | View | MEMORANDUM OPINION AND ORDER granting in part and denying in part Defendant's Motion for Judgment on the Pleadings, Dkt. 37 . See document for details. Signed by Judge Randolph D. Moss on 5/19/2020. (lcrdm1) (Entered: 05/19/2020) |
| 111 | May 21, 2020 | View | Joint MOTION for Extension of Time to File Documents With Respect to Plaintiffs' Motion for Conditional Certification by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Attachments: # 1 Text of Proposed Order)(Kornblith, Russell) (Entered: 05/21/2020) |
| May 21, 2020 | MINUTE ORDER: Upon consideration of the parties' joint motion for extension, Dkt. 111 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED the Plaintiffs shall file their motion for leave to amend and/or supplement their Conditional Certification Motion on or before June 9, 2020. It is further ORDERED that Defendant shall file its opposition to Plaintiffs' amended Motion for Conditional Certification on or before July 13, 2020. Signed by Judge Randolph D. Moss on 5/21/2020. (lcrdm1) (Entered: 05/21/2020) | ||
| May 22, 2020 | MINUTE ORDER: Upon consideration of Defendant's sealed consent motion to file under seal, Dkt. 104 , it is hereby ORDERED that the motion is GRANTED. Signed by Judge Randolph D. Moss on 5/22/2020. (lcrdm1) (Entered: 05/22/2020) | ||
| 112 | May 22, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Text of Proposed Order)(Kornblith, Russell) (Entered: 05/22/2020) |
| 113 | May 22, 2020 | Request | SEALED DOCUMENT filed by JONES DAY. (This document is SEALED and only available to authorized persons.)(ztd) (Entered: 05/26/2020) |
| May 26, 2020 | MINUTE ORDER: Upon consideration of the parties' joint motion for leave to file under seal, Dkt. 112 , it is hereby ORDERED that the motion is GRANTED. In light of the Court's memorandum opinion and order granting in part and denying in part Defendant's motion for partial judgment on the pleadings, it is further ORDERED that the parties shall appear telephonically on June 10, 2020 at 10:00 a.m. for a scheduling conference to discuss next steps in the litigation, including discovery. Signed by Judge Randolph D. Moss on 5/26/2020. (lcrdm1) (Entered: 05/26/2020) | ||
| 114 | May 26, 2020 | Request | SEALED DOCUMENT (Main Document is Exhibit A) filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit B)(ztd) (Entered: 05/26/2020) |
| 115 | May 26, 2020 | View | Memorandum in opposition to re 68 MOTION for Sanctions (Rule 11) (REDACTED PER COURT'S ORDERS) filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (Attachments: # 1 Declaration of Russell L. Kornblith, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Exhibit P, # 18 Text of Proposed Order)(Kornblith, Russell) (Entered: 05/26/2020) |
| Jun 9, 2020 | MINUTE ORDER: Upon consideration of Defendant's motion for sanctions, Dkt. 73 , it is hereby ORDERED that the motion is DENIED without prejudice. Jones Day argues that Plaintiffs brought their claims "that Jones Day paid men more than women," without factual basis or investigation, and while ignoring evidence that undermined those claims. Dkt. 68 at 1. Federal Rule of Civil Procedure 11(b)(3) provides that "[b]y presenting to the court a pleading... an attorney... certifies that to the best of the persons knowledge, information, and belief, formed after an inquiry reasonable under the circumstances... [that] the factual contentions have evidentiary support or, if specifically identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery." To the extent that Jones Day argues that Plaintiffs failed adequately to investigate their claims before initiating this lawsuit, the Court is unconvinced. First, "[w]hat constitutes 'reasonable inquiry' depends on the circumstances of the case." Duncan v. WJLA-TV, Inc., 106 F.R.D. 4, 6 (D.D.C. 1984). Here, Plaintiffs faced two considerable challenges in conducting a pre-filing investigation into pay disparities - both an alleged formal pay secrecy policy disincentivizing others from sharing their pay information with Plaintiffs and a lack of access to Defendant's organizational pay data. Second, Rule 11 "is not intended to chill an attorney's enthusiasm or creativity in pursuing factual or legal theories. The [C]ourt is expected to avoid using the wisdom of hindsight and should test the signer's conduct by inquiring what was reasonable to believe at the time the pleading, motion, or other paper was submitted." Fed. R. Civ. P. 11 Advisory Committee Notes. Although Defendant may dispute the legal sufficiency of Plaintiffs' basing their claims in part on (1) Defendant's alleged failure to pay Plaintiffs at "Cravath" rates, (2) Plaintiffs' theory extrapolating pay disparities from incidents of alleged gendered harassment, and (3) disproportionate ratios of men in the firm's partnership, these theories are not so frivolous or beyond-the-pale to warrant sanctions. Third, Jones Day argues that Plaintiffs ignored evidence that undermined or contradicted their allegations, but a Plaintiff is not prevented from bringing a claim simply because she encounters some evidence that does not support her theory. To the extent that Jones Day argues that the claims brought by Plaintiffs are objectively without factual support, Jones Day's motion for sanctions relies on factual assertions made by Jones Day pertaining to both Plaintiffs' and third parties' compensation and work. It would be premature for the Court to pass on the veracity of these assertions in deciding Defendant's motion for Rule 11 sanctions at this stage in the litigation, before Plaintiffs have had the opportunity to conduct relevant discovery. A pre-discovery motion for Rule 11 sanctions is not an appropriate substitute for a motion for summary judgment. Cf. Hedgeye Risk Mgmt., LLC v. Heldman, 412 F. Supp. 3d 15, 35 (D.D.C. 2019) (discussing a plaintiff's ability to rely on discovery to develop evidence for claims that it brought based on "sufficient circumstantial evidence objectively and reasonably to infer" that the defendant was liable for the claim alleged); Quick v. EduCap, Inc., No. 17-1242, 2019 WL 95566, *2 (D.D.C. Jan. 3, 2019) (discussing general inappropriateness of granting a motion for sanctions "[a]t the pleading stage," when "ordinarily there is little or no evidence before the Court at all" (quoting Tahfs v. Proctor, 316 F.3d 584, 595 (6th Cir. 2003))). Finally, the Court stresses that "Rule 11 sanctions are a harsh punishment," Robinson-Reeder v. Am. Council on Educ., 626 F. Supp. 2d 11, 18 (D.D.C. 2009) (quoting Sharp v. Rosa Mexicano, D.C., LLC, 496 F. Supp. 2d 93, 100 (D.D.C. 2007)), which a court should impose only when those sanctions are clearly warranted. Here, the Court does not yet know enough about the relevant facts to determine whether Plaintiffs' allegations are so baseless that sanctions are warranted. Rule 11 is intended to deter and to punish litigation abuses. It is not a means of obtaining an early resolution of the merits of a dispute. It is further ORDERED that Plaintiffs' motion for leave to file surreply, Dkt. 99 , is hereby GRANTED. Signed by Judge Randolph D. Moss on 6/9/2020. (lcrdm1) Modified on 6/10/2020 to correct typo (kt). (Entered: 06/09/2020) | ||
| 116 | Jun 9, 2020 | View | SURREPLY to re 102 MOTION for Sanctions (REDACTED PER COURT'S ORDER - DKT. 89 AND 1/31/2020 MINUTE ORDER) filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (ztd) (Entered: 06/09/2020) |
| 117 | Jun 9, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Text of Proposed Order, # 2 Exhibit, # 3 Text of Proposed Order, # 4 Notice to Counsel/Party, # 5 Text of Proposed Order, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19 Exhibit, # 20 Exhibit, # 21 Exhibit, # 22 Exhibit, # 23 Exhibit, # 24 Exhibit, # 25 Errata, # 26 Exhibit, # 27 Exhibit, # 28 Exhibit, # 29 Exhibit, # 30 Exhibit, # 31 Exhibit, # 32 Exhibit, # 33 Exhibit, # 34 Exhibit, # 35 Exhibit, # 36 Exhibit, # 37 Exhibit, # 38 Exhibit, # 39 Exhibit, # 40 Exhibit, # 41 Exhibit, # 42 Exhibit, # 43 Exhibit, # 44 Exhibit, # 45 Exhibit, # 46 Exhibit, # 47 Exhibit, # 48 Exhibit, # 49 Exhibit, # 50 Exhibit)(Marcuse, Deborah) (Entered: 06/09/2020) |
| 118 | Jun 9, 2020 | View | Amended MOTION for Leave to File Conditional Certification by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Attachments: # 1 Exhibit, # 2 Notice to Counsel/Party, # 3 Text of Proposed Order, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19 Exhibit, # 20 Exhibit, # 21 Exhibit, # 22 Exhibit, # 23 Exhibit, # 24 Exhibit, # 25 Exhibit, # 26 Exhibit, # 27 Exhibit, # 28 Exhibit, # 29 Exhibit, # 30 Exhibit, # 31 Exhibit, # 32 Exhibit, # 33 Exhibit, # 34 Exhibit, # 35 Exhibit, # 36 Exhibit, # 37 Exhibit, # 38 Exhibit, # 39 Exhibit, # 40 Exhibit, # 41 Exhibit, # 42 Exhibit, # 43 Exhibit, # 44 Exhibit, # 45 Exhibit, # 46 Declaration)(Marcuse, Deborah) (Entered: 06/10/2020) |
| Jun 10, 2020 | NOTICE OF ERROR re 118 Motion for Leave to File; emailed to dmarcuse@sanfordheisler.com, cc'd 24 associated attorneys -- The PDF file you docketed contained errors: 1. Reminder FYI: If you are electronically filing, your name must appear on the signature line of the document(s) and vice versa. (ztd, ) (Entered: 06/10/2020) | ||
| Jun 10, 2020 | NOTICE OF ERROR re 117 Sealed Motion for Leave to File Document Under Seal; emailed to dmarcuse@sanfordheisler.com, cc'd 24 associated attorneys -- The PDF file you docketed contained errors: 1. Reminder FYI: If you are electronically filing, your name must appear on the signature line of the document(s) and vice versa. (ztd, ) (Entered: 06/10/2020) | ||
| Jun 10, 2020 | Minute Entry for proceedings held before Judge Randolph D. Moss: Telephonic Scheduling Conference held on 6/10/2020. The parties, and the Court, appeared via telephone. Plaintiffs shall file their Motion for Class Certification by 1/15/2021; Defendants' Opposition to the Motion and Motion for Summary Judgment due by 2/12/2021; Plaintiffs' Reply to the Motion and Response to Motion for Summary Judgment due by 3/5/2021; Defendants' Reply to Motion for Summary Judgment due by 3/19/2021. All expert and fact discovery shall be completed by 6/11/2021. Plaintiffs' Motion for Leave to Amend the Third Amended Complaint due by 6/26/2020; Defendants' Opposition due by 7/15/2020; Plaintiffs' Reply due by 7/29/2020. Defendants' letters regarding discovery issues due by 6/19/2020; Plaintiffs' response due by 7/3/2020. A Telephonic Status Conference is set for 7/9/2020. at 11:15 AM, before Judge Randolph D. Moss. The parties shall utilize the same conference call number and access code. (Court Reporter Jeff Hook.) (kt) (Entered: 06/11/2020) | ||
| 119 | Jun 15, 2020 | Request | TRANSCRIPT OF TELEPHONIC SCHEDULING CONFERENCE before Judge Randolph D. Moss held on June 10, 2020. Page Numbers: 1 - 43. Date of Issuance: June 15, 2020. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court rep orter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 7/6/2020. Redacted Transcript Deadline set for 7/16/2020. Release of Transcript Restriction set for 9/13/2020.(Hook, Jeff) (Entered: 06/15/2020) |
| 120 | Jun 19, 2020 | View | ENTERED IN ERROR. . . . . MOTION for Protective Order Discovery Letter Requested by the Court on 6/10/2020 by JONES DAY (Chase, Terri) Modified on 6/19/2020 (ztd). (Entered: 06/19/2020) |
| Jun 19, 2020 | NOTICE OF ERROR re 120 Motion for Protective Order; emailed to tlchase@jonesday.com, cc'd 26 associated attorneys -- The PDF file you docketed contained errors: 1. Please refile document, 2. Incorrect format. See LcvR 5.1(a) & (d). (ztd, ) (Entered: 06/19/2020) | ||
| 121 | Jul 3, 2020 | View | RESPONSE re 120 MOTION for Protective Order Discovery Letter Requested by the Court on 6/10/2020 filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (Mueting, Katie) (Entered: 07/03/2020) |
| Jul 8, 2020 | MINUTE ORDER: Upon consideration of Plaintiffs' motion to file provisionally under seal, Dkt. 117 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Plaintiffs may provisionally file unredacted versions of their amended memorandum of law and supporting exhibited under seal. Signed by Judge Randolph D. Moss on 7/8/2020. (lcrdm1) (Entered: 07/08/2020) | ||
| 122 | Jul 8, 2020 | Request | SEALED MOTION filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Text of Proposed Order, # 2 Notice, # 3 Text of Proposed Order); (EXHIBITS SEE DOCKET ENTRY NO. 117 TO VIEW.)(ztd) (Entered: 07/09/2020) |
| Jul 9, 2020 | Minute Entry for proceedings held before Judge Randolph D. Moss: Telephonic Status Conference held on 7/9/2020. The Court authorizes nationwide discovery of associate compensation and numerical evaluation data for the period from January 1, 2012 to December 31, 2018. Plaintiffs' deadline to file their Motion for Class Certification is extended to 3/31/2021; Opposition due by 5/5/2021; Reply due by 6/4/2021. (Court Reporter: Jeff Hook.) (kt) Modified on 7/9/2020 to include ruling re: discovery (kt). (Entered: 07/09/2020) | ||
| 123 | Jul 13, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Chase Declaration, # 2 Exhibit 3, # 3 Exhibit 7, # 4 Exhibit 14, # 5 Exhibit 20, # 6 Exhibit 21, # 7 Exhibit 22, # 8 Exhibit 23, # 9 Exhibit 24, # 10 Exhibit 25, # 11 Exhibit 26, # 12 Exhibit 28, # 13 Exhibit 29, # 14 Exhibit Coussons 1, # 15 Text of Proposed Order)(Powers, MaryEllen) (Entered: 07/13/2020) |
| 124 | Jul 13, 2020 | View | ENTERED IN ERROR.....Memorandum in opposition to re 118 Amended MOTION for Leave to File Conditional Certification filed by JONES DAY. (Attachments: # 1 Declaration of Darren Cottriel, # 2 Declaration of Richard Deane, # 3 Declaration of Anthony M. Insogna, # 4 Declaration of Colleen E. Laduzinski, # 5 Declaration of Traci Lovitt, # 6 Declaration of Christopher Lovrien, # 7 Declaration of Stephanie E. Parker, # 8 Declaration of Lizanne Thomas, # 9 Declaration of Suzanne Coussons, # 10 Exhibit 1, # 11 Declaration of Terri L. Chase, # 12 Exhibit 1, # 13 Exhibit 2, # 14 Exhibit 3, # 15 Exhibit 4, # 16 Exhibit 5, # 17 Exhibit 6, # 18 Exhibit 7, # 19 Exhibit 8, # 20 Exhibit 9, # 21 Exhibit 10, # 22 Exhibit 11, # 23 Exhibit 12, # 24 Exhibit 13, # 25 Exhibit 14, # 26 Exhibit 15, # 27 Exhibit 16, # 28 Exhibit 17, # 29 Exhibit 18, # 30 Exhibit 19, # 31 Exhibit 20, # 32 Exhibit 21, # 33 Exhibit 22, # 34 Exhibit 23, # 35 Exhibit 24, # 36 Exhibit 25, # 37 Exhibit 26, # 38 Exhibit 27, # 39 Exhibit 28, # 40 Exhibit 29)(Powers, MaryEllen) (Entered: 07/13/2020) |
| 125 | Jul 13, 2020 | View | Memorandum in opposition to re 118 Amended MOTION for Leave to File Conditional Certification (CORRECTED) filed by JONES DAY. (Attachments: # 1 Declaration of Darren Cottriel, # 2 Declaration of Richard Deane, # 3 Declaration of Anthony M. Insogna, # 4 Declaration of Colleen E. Laduzinski, # 5 Declaration of Traci Lovitt, # 6 Declaration of Christopher Lovrien, # 7 Declaration of Stephanie E. Parker, # 8 Declaration of Lizanne Thomas, # 9 Declaration of Suzanne Coussons, # 10 Exhibit 1, # 11 Declaration of Terri L. Chase, # 12 Exhibit 1, # 13 Exhibit 2, # 14 Exhibit 3, # 15 Exhibit 4, # 16 Exhibit 5, # 17 Exhibit 6, # 18 Exhibit 7, # 19 Exhibit 8, # 20 Exhibit 9, # 21 Exhibit 10, # 22 Exhibit 11, # 23 Exhibit 12, # 24 Exhibit 13, # 25 Exhibit 14, # 26 Exhibit 15, # 27 Exhibit 16, # 28 Exhibit 17, # 29 Exhibit 18, # 30 Exhibit 19, # 31 Exhibit 20, # 32 Exhibit 21, # 33 Exhibit 22, # 34 Exhibit 23, # 35 Exhibit 24, # 36 Exhibit 25, # 37 Exhibit 26, # 38 Exhibit 27, # 39 Exhibit 28, # 40 Exhibit 29)(Powers, MaryEllen) (Entered: 07/13/2020) |
| 126 | Jul 13, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Defendants Motion For Summary Judgment On Count IV (Equal Pay Act), # 2 Exhibit Defendant's Statement of Undisputed Material Facts, # 3 Exhibit Declaration of Lori Bounds, # 4 Text of Proposed Order)(Powers, MaryEllen) (Entered: 07/13/2020) |
| 127 | Jul 13, 2020 | View | MOTION for Summary Judgment on Count IV (Equal Pay Act) by JONES DAY (Attachments: # 1 Statement of Facts (Undisputed Material), # 2 Declaration of Lori Bounds, # 3 Text of Proposed Order)(Powers, MaryEllen) (Entered: 07/13/2020) |
| Jul 14, 2020 | NOTICE OF CORRECTED DOCKET ENTRY: re 124 Memorandum in Opposition, was entered in error at the request of counsel. Said pleading was refiled by counsel as docket entry 125 . (ztth) (Entered: 07/14/2020) | ||
| Jul 14, 2020 | MINUTE ORDER: In light of Defendant's filing with the Court's permission of its motion for summary judgment on the Equal Pay Act claims, Dkt. 127 , as well as the Court's usual practice under its standing order of holding a conference with the parties in anticipation of the filing of a motion for summary judgment to discuss the grounds for that motion as well as the anticipated response, it is hereby ORDERED that the parties shall appear telephonically on July 21, 2020 at 2:30 p.m. to discuss Defendant's motion and Plaintiffs' anticipated response to that motion. The parties shall use the same dial-in and access code that has been previously provided to them. Signed by Judge Randolph D. Moss on 7/14/2020. (lcrdm1) (Entered: 07/14/2020) | ||
| 128 | Jul 15, 2020 | View | Memorandum in opposition to re 118 Amended MOTION for Leave to File Conditional Certification (Second Corrected) filed by JONES DAY. (Attachments: # 1 Declaration of Darren Cottriel, # 2 Declaration of Richard Deane, # 3 Declaration of Anthony M. Insogna, # 4 Declaration of Colleen E. Laduzinski, # 5 Declaration of Traci Lovitt, # 6 Declaration of Christopher Lovrien, # 7 Declaration of Stephanie E. Parker, # 8 Declaration of Lizanne Thomas, # 9 Declaration of Suzanne Coussons, # 10 Exhibit 1, # 11 Declaration of Terri L. Chase, # 12 Exhibit 1, # 13 Exhibit 2, # 14 Exhibit 3, # 15 Exhibit 4, # 16 Exhibit 5, # 17 Exhibit 6, # 18 Exhibit 7, # 19 Exhibit 8, # 20 Exhibit 9, # 21 Exhibit 10, # 22 Exhibit 11, # 23 Exhibit 12, # 24 Exhibit 13, # 25 Exhibit 14, # 26 Exhibit 15, # 27 Exhibit 16, # 28 Exhibit 17, # 29 Exhibit 18, # 30 Exhibit 19, # 31 Exhibit 20, # 32 Exhibit 21, # 33 Exhibit 22, # 34 Exhibit 23, # 35 Exhibit 24, # 36 Exhibit 25, # 37 Exhibit 26, # 38 Exhibit 27, # 39 Exhibit 28, # 40 Exhibit 29)(Powers, MaryEllen) (Entered: 07/15/2020) |
| 129 | Jul 15, 2020 | View | MOTION for Summary Judgment on Count IV (Equal Pay Act) (CORRECTED) by JONES DAY (Attachments: # 1 Statement of Facts (Undisputed Material), # 2 Declaration of Lori Bounds, # 3 Text of Proposed Order)(Powers, MaryEllen) (Entered: 07/15/2020) |
| Jul 17, 2020 | MINUTE ORDER: Upon consideration of Defendant's sealed motion for leave to file document provisionally under seal, Dkt. 123 , it is hereby ordered that the motion is GRANTED. Upon consideration of Defendant's sealed motion for leave to file document provisionally under seal, Dkt. 126 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Defendant may file the documents in question provisionally under seal. It is further ORDERED that, if neither party moves to seal the documents on or before July 27, 2020, Defendant shall promptly file the documents in unredacted form on the public docket. Signed by Judge Randolph D. Moss on 7/17/2020. (lcrdm1) (Entered: 07/17/2020) | ||
| Jul 17, 2020 | MINUTE ORDER: Upon consideration of Plaintiffs' motion for leave to amend motion for conditional certification of an Equal Pay Act Collective Action and Authorization of Notice, Dkt. 118 , Dkt. 122 , it is hereby ORDERED that the motion is GRANTED. Plaintiffs move for leave to file an amended motion for conditional certification, representing that Defendant did not consent to the filing of that motion. Dkt. 118 at 3; Dkt. 122 at 3. Defendant, however, has not specifically opposed the motion for leave to file an amended motion and, instead, has filed an opposition to the motion for conditional certification that is addressed to the amended motion and treats that motion as the operative motion. See Dkt. 128. In light of these circumstances, the Court will treat the motion for leave to file an amended motion as unopposed. Accordingly, it is hereby ORDERED that Plaintiffs may file their amended motion for conditional certification of an Equal Pay Act Collective Action and Authorization of Notice. It is further ORDERED that Plaintiffs' previous motion to certify class conditionally under the Equal Pay Act, Dkt. 65 ; Dkt. 94 , is hereby DENIED as moot. Signed by Judge Randolph D. Moss on 7/17/2020. (lcrdm1) (Entered: 07/17/2020) | ||
| 130 | Jul 17, 2020 | Request | TRANSCRIPT OF TELEPHONIC STATUS CONFERENCE before Judge Randolph D. Moss held on July 9, 2020. Page Numbers: 1 - 56. Date of Issuance: July 17, 2020. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 8/7/2020. Redacted Transcript Deadline set for 8/17/2020. Release of Transcript Restriction set for 10/15/2020.(Hook, Jeff) (Entered: 07/17/2020) |
| 131 | Jul 17, 2020 | View | MOTION for Extension of Time to Oppose Motion for Summary Judgment by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Attachments: # 1 Text of Proposed Order)(Kornblith, Russell) (Entered: 07/17/2020) |
| 133 | Jul 17, 2020 | Request | SEALED DOCUMENT filed by JONES DAY. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 3, # 2 Exhibit 7, # 3 Exhibit 14, # 4 Exhibit 20, # 5 Exhibit 21, # 6 Exhibit 22, # 7 Exhibit 23, # 8 Exhibit 24, # 9 Exhibit 25, # 10 Exhibit 26, # 11 Exhibit 28, # 12 Exhibit 29, # 13 Coussons)(ztd) (Entered: 07/20/2020) |
| 134 | Jul 17, 2020 | Request | SEALED MOTION filed by JONES DAY. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Statement of Facts, # 2 Declaration)(ztd) (Entered: 07/20/2020) |
| Jul 20, 2020 | MINUTE ORDER: Upon consideration of Plaintiffs' motion for extension of time, Dkt. 131 , it is hereby ORDERED that Defendant shall respond to that motion before 5:00 p.m. on July 21, 2020. Signed by Judge Randolph D. Moss on 7/20/2020. (lcrdm1) (Entered: 07/20/2020) | ||
| 132 | Jul 20, 2020 | View | RESPONSE re 131 MOTION for Extension of Time to Oppose Motion for Summary Judgment filed by JONES DAY. (Attachments: # 1 Exhibit Exhibit A)(Powers, MaryEllen) (Entered: 07/20/2020) |
| 135 | Jul 20, 2020 | View | REPLY to opposition to motion re 118 Amended MOTION for Leave to File Conditional Certification filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (Mueting, Katie) (Entered: 07/20/2020) |
| Jul 21, 2020 | Minute Entry for proceedings held before Judge Randolph D. Moss: Telephone Conference held on 7/21/2020. Plaintiffs shall provide Defendant a copy of their Rule 56(d) Affidavit/Declaration by close of business on 7/24/2020, and to the Court by close of business on 7/31/2020. The Court grants in part and denies in part Plaintiffs' 131 Motion for Extension of Time to Oppose Motion for Summary Judgment; Response due by 8/10/2020. A further Telephone Conference is set for 8/3/2020, at 2:00 PM, before Judge Randolph D. Moss. The parties shall utilize the same teleconference line and access code. (Court Reporter: Jeff Hook.) (kt) (Entered: 07/21/2020) | ||
| 136 | Jul 27, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Declaration of Michael R. Shumaker, # 2 Declaration of Traci L. Lovitt, # 3 Exhibit Mem. of Law, # 4 Exhibit A, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit I, # 8 Exhibit J, # 9 Exhibit K, # 10 Exhibit N, # 11 Exhibit O, # 12 Exhibit P, # 13 Exhibit R, # 14 Exhibit S, # 15 Exhibit T, # 16 Exhibit U, # 17 Exhibit W, # 18 Exhibit X, # 19 Exhibit Y, # 20 Exhibit Z, # 21 Exhibit AA, # 22 Exhibit BB, # 23 Exhibit CC, # 24 Exhibit GG, # 25 Exhibit HH, # 26 Exhibit II, # 27 Exhibit LL, # 28 Exhibit QQ, # 29 Text of Proposed Order)(Powers, MaryEllen) (Entered: 07/27/2020) |
| 137 | Jul 27, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Chase Decl., # 2 Exhibit Chase 3, # 3 Exhibit Chase 7, # 4 Exhibit Chase 14, # 5 Exhibit Chase 20, # 6 Exhibit Chase 21, # 7 Exhibit Chase 22, # 8 Exhibit Chase 23, # 9 Exhibit Chase 24, # 10 Exhibit Chase 25, # 11 Exhibit Chase 26, # 12 Exhibit Chase 28, # 13 Exhibit Chase 29, # 14 Exhibit Coussons 1, # 15 Text of Proposed Order)(Powers, MaryEllen) (Entered: 07/27/2020) |
| 138 | Jul 27, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Mem. of Law, # 2 Exhibit Stmt. of Undisputed Material Facts, # 3 Exhibit Bounds Decl., # 4 Text of Proposed Order)(Powers, MaryEllen) (Entered: 07/27/2020) |
| Aug 3, 2020 | Minute Entry for proceedings held before Judge Randolph D. Moss: Telephone Conference held on 8/3/2020. For the reasons stated on the record, the 56(b) Motion is denied, without prejudice. Plaintiffs' Opposition to the 129 Motion for Summary Judgment on Count IV is due by 8/21/2020; Defendant's Reply is due by 9/11/2020. (Court Reporter: Jeff Hook.) (kt) (Entered: 08/03/2020) | ||
| Aug 3, 2020 | MINUTE ORDER: Upon consideration of the parties' joint motion to seal portions of Plaintiffs' amended memorandum in support of their motion for conditional certification of an Equal Pay Act collective action and authorization of notice and certain of the accompanying exhibits, Dkt. 136 , it is hereby ORDERED that the motion is GRANTED. Upon consideration of the parties' motion to seal portions of the materials accompanying Defendant's memorandum in opposition to Plaintiffs' amended motion for conditional certification of an Equal Pay Act collective action and authorization of notice, Dkt. 137 , it is hereby ORDERED that the motion is GRANTED. Upon consideration of Defendant's unopposed motion to seal portions of its motion for summary judgment on Count IV, Dkt. 138 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that the parties shall refile on the public docket the relevant documents with redactions consistent with this order. It is further ORDERED that, in publicly filed exhibits, the names of Plaintiffs' alleged comparators shall be replaced with anonymizers, as indicated in the parties' motions. Signed by Judge Randolph D. Moss on 8/3/2020. (lcrdm1) (Entered: 08/03/2020) | ||
| 142 | Aug 3, 2020 | View | SEALED DOCUMENT filed by JONES DAY. (This document is SEALED and only available to authorized persons.); (SEE DOCKET ENTRY NO.136 TO VIEW.)(ztd) (Entered: 08/07/2020) |
| 143 | Aug 3, 2020 | Request | SEALED DOCUMENT filed by JONES DAY. (This document is SEALED and only available to authorized persons.); (SEE DOCKET ENTRY NO.137 TO VIEW.)(ztd) (Entered: 08/07/2020) |
| 144 | Aug 3, 2020 | View | SEALED MOTION filed by JONES DAY. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Statement of Facts, # 2 Declaration)(ztd) (Entered: 08/07/2020) |
| 139 | Aug 6, 2020 | Request | AFFIDAVIT of Russell Kornblith for Discovery by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (Kornblith, Russell) (Entered: 08/06/2020) |
| 140 | Aug 6, 2020 | Request | TRANSCRIPT OF TELEPHONE CONFERENCE before Judge Randolph D. Moss held on August 3, 2020. Page Numbers: 1 - 61. Date of Issuance: August 6, 2020. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court report er referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 8/27/2020. Redacted Transcript Deadline set for 9/6/2020. Release of Transcript Restriction set for 11/4/2020.(Hook, Jeff) (Entered: 08/06/2020) |
| 141 | Aug 6, 2020 | Request | RESPONSE re 139 Affidavit of Russell Kornblith for Discovery filed by JONES DAY. (Powers, MaryEllen) (Entered: 08/06/2020) |
| 145 | Aug 7, 2020 | View | Amended MOTION to Certify Class Conditionally Under the Equal Pay Act (REDACTED PER COURT'S AUG. 3 MINUTE ORDER) by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Attachments: # 1 Memorandum in Support, # 2 Declaration of Kate Mueting, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I, # 12 Exhibit J, # 13 Exhibit K, # 14 Exhibit L, # 15 Exhibit M, # 16 Exhibit N, # 17 Exhibit O, # 18 Exhibit P, # 19 Exhibit Q, # 20 Exhibit R, # 21 Exhibit S, # 22 Exhibit T, # 23 Exhibit U, # 24 Exhibit V, # 25 Exhibit W, # 26 Exhibit X, # 27 Exhibit Y, # 28 Exhibit Z, # 29 Exhibit AA, # 30 Exhibit BB, # 31 Exhibit CC, # 32 Exhibit DD, # 33 Exhibit EE, # 34 Exhibit FF, # 35 Exhibit GG, # 36 Exhibit HH, # 37 Exhibit II, # 38 Exhibit JJ, # 39 Exhibit KK, # 40 Exhibit LL, # 41 Exhibit MM, # 42 Exhibit NN, # 43 Exhibit OO, # 44 Exhibit PP, # 45 Exhibit QQ, # 46 Text of Proposed Order)(Mueting, Katie) (Entered: 08/07/2020) |
| 146 | Aug 7, 2020 | View | Memorandum in opposition to re 145 Amended MOTION to Certify Class Conditionally Under the Equal Pay Act (REDACTED PER COURT'S AUG. 3 MINUTE ORDER) (REDACTED PER COURT'S AUG. 3 MINUTE ORDER) filed by JONES DAY. (Attachments: # 1 Declaration of Darren Cottriel, # 2 Declaration of Richard Deane, # 3 Declaration of Anthony M. Insogna, # 4 Declaration of Colleen E. Laduzinski, # 5 Declaration of Traci Lovitt, # 6 Declaration of Christopher Lovrien, # 7 Declaration of Stephanie E. Parker, # 8 Declaration of Lizanne Thomas, # 9 Declaration of Suzanne Coussons, # 10 Exhibit 1, # 11 Declaration of Terri L. Chase, # 12 Exhibit 1, # 13 Exhibit 2, # 14 Exhibit 3, # 15 Exhibit 4, # 16 Exhibit 5, # 17 Exhibit 6, # 18 Exhibit 7, # 19 Exhibit 8, # 20 Exhibit 9, # 21 Exhibit 10, # 22 Exhibit 11, # 23 Exhibit 12, # 24 Exhibit 13, # 25 Exhibit 14, # 26 Exhibit 15, # 27 Exhibit 16, # 28 Exhibit 17, # 29 Exhibit 18, # 30 Exhibit 19, # 31 Exhibit 20, # 32 Exhibit 21, # 33 Exhibit 22, # 34 Exhibit 23, # 35 Exhibit 24, # 36 Exhibit 25, # 37 Exhibit 26, # 38 Exhibit 27, # 39 Exhibit 28, # 40 Exhibit 29)(Powers, MaryEllen) (Entered: 08/07/2020) |
| 147 | Aug 7, 2020 | View | MOTION for Summary Judgment on Count IV (Equal Pay Act) (REDACTED PER COURT'S AUG. 3 MINUTE ORDER) by JONES DAY (Attachments: # 1 Statement of Facts (Undisputed Material), # 2 Declaration of Lori Bounds, # 3 Text of Proposed Order)(Powers, MaryEllen) (Entered: 08/07/2020) |
| 148 | Aug 7, 2020 | Request | TRANSCRIPT OF TELEPHONIC PRE-MOTION CONFERENCE before Judge Randolph D. Moss held on July 21, 2020. Page Numbers: 1 - 31. Date of Issuance: August 7, 2020. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 8/28/2020. Redacted Transcript Deadline set for 9/7/2020. Release of Transcript Restriction set for 11/5/2020.(Hook, Jeff) (Entered: 08/07/2020) |
| 149 | Aug 21, 2020 | View | Memorandum in opposition to re 147 MOTION for Summary Judgment on Count IV (Equal Pay Act) (REDACTED PER COURT'S AUG. 3 MINUTE ORDER) filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (Attachments: # 1 Declaration of Russell L. Kornblith, # 2 Exhibit A1, # 3 Exhibit A2, # 4 Exhibit A3, # 5 Exhibit B1, # 6 Exhibit B2, # 7 Exhibit B3, # 8 Exhibit B4, # 9 Exhibit B5, # 10 Exhibit C1, # 11 Exhibit C2, # 12 Exhibit C3, # 13 Exhibit C4, # 14 Exhibit C5, # 15 Exhibit C6, # 16 Exhibit C7, # 17 Exhibit C8, # 18 Exhibit C9, # 19 Exhibit C10, # 20 Exhibit C11, # 21 Exhibit C12, # 22 Exhibit C13, # 23 Exhibit C14, # 24 Exhibit C15, # 25 Exhibit C16, # 26 Exhibit C17, # 27 Exhibit C18, # 28 Exhibit C19, # 29 Exhibit C20, # 30 Exhibit C21, # 31 Exhibit C22, # 32 Exhibit C23, # 33 Exhibit C24, # 34 Exhibit D1, # 35 Exhibit D2, # 36 Exhibit D3, # 37 Exhibit D4, # 38 Exhibit D5, # 39 Exhibit D6, # 40 Exhibit D7, # 41 Exhibit D8, # 42 Exhibit D9, # 43 Exhibit D10, # 44 Exhibit E1, # 45 Exhibit E2, # 46 Exhibit E3, # 47 Exhibit F1, # 48 Exhibit F2, # 49 Exhibit G1, # 50 Exhibit G2, # 51 Exhibit G3, # 52 Exhibit G4, # 53 Exhibit G5, # 54 Exhibit G6, # 55 Statement of Facts Response and Additional Facts, # 56 Text of Proposed Order Denying Summary Judgment)(Kornblith, Russell) (Entered: 08/21/2020) |
| 150 | Aug 21, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Text of Proposed Order Granting Motion to Seal, # 2 Exhibit in Opposition to Summary Judgment, # 3 Statement of Facts in Response and Additional Facts, # 4 Declaration of Russell L. Kornblith)(Kornblith, Russell) (Entered: 08/21/2020) |
| 151 | Aug 21, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit A1, # 2 Exhibit A2, # 3 Exhibit B1, # 4 Exhibit B2, # 5 Exhibit B3, # 6 Exhibit B4, # 7 Exhibit B5, # 8 Exhibit C1, # 9 Exhibit C2, # 10 Exhibit C3, # 11 Exhibit C4, # 12 Exhibit C5)(Kornblith, Russell) (Entered: 08/22/2020) |
| 152 | Aug 22, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit C6, # 2 Exhibit C7, # 3 Exhibit C8, # 4 Exhibit C9, # 5 Exhibit C10)(Kornblith, Russell) (Entered: 08/22/2020) |
| 153 | Aug 22, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit C11, # 2 Exhibit C12, # 3 Exhibit C13, # 4 Exhibit C14, # 5 Exhibit C15, # 6 Exhibit C16, # 7 Exhibit C17, # 8 Exhibit C18, # 9 Exhibit C19, # 10 Exhibit C20, # 11 Exhibit C21, # 12 Exhibit C22, # 13 Exhibit C23, # 14 Exhibit C24)(Kornblith, Russell) (Entered: 08/22/2020) |
| 154 | Aug 22, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit D1, # 2 Exhibit D2, # 3 Exhibit D3, # 4 Exhibit D4, # 5 Exhibit D5, # 6 Exhibit D6, # 7 Exhibit D7, # 8 Exhibit D9, # 9 Exhibit D10)(Kornblith, Russell) (Entered: 08/22/2020) |
| 155 | Aug 22, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit E2, # 2 Exhibit G1, # 3 Exhibit G2, # 4 Exhibit G3, # 5 Exhibit G4, # 6 Exhibit G5, # 7 Exhibit G6)(Kornblith, Russell) (Entered: 08/22/2020) |
| Aug 26, 2020 | MINUTE ORDER: Upon consideration of Plaintiffs' motions for leave to file provisionally under seal, Dkt. 150 , Dkt. 151 , Dkt. 152 , Dkt. 153 , Dkt. 154 , and Dkt. 155 , it is hereby ORDERED that the motions are GRANTED. It is further ORDERED that the parties shall confer and, on or before September 10, 2020, shall jointly file a motion to seal along with public versions of materials with agreed-upon proposed redactions for each exhibit for which redactions are sought by either party. If any disputes remain pertaining to certain exhibits following the parties' conferral, each party shall also file, at the same time, separate copies of each disputed exhibit under seal, including the proposed redactions that the party deems appropriate, and the parties shall also file a joint status report explaining the basis for the parties' dispute regarding each redaction upon which the parties cannot agree. The Court notes that "the starting point in considering a motion to seal court records is a 'strong presumption in favor of public access to judicial proceedings.'" EEOC v. National Children's Center, Inc., 98 F.3d 1406, 1409 (D.C. Cir. 1996) (quoting Johnson v. Greater Southeast Cmty. Hosp. Corp., 951 F.2d 1268, 1277 (D.C. Cir. 1991)). Signed by Judge Randolph D. Moss on 08/26/2020. (lcrdm1) (Entered: 08/26/2020) | ||
| 156 | Sep 9, 2020 | View | MOTION for Leave to File Amica Curiae Brief by JULIA SHEKETOFF (Attachments: # 1 Exhibit Proposed Brief of Amica Curiae Julia Sheketoff, # 2 Text of Proposed Order)(Sheketoff, Julia) (Entered: 09/09/2020) |
| Sep 10, 2020 | MINUTE ORDER: Upon consideration of Julia Sheketoffs motion to file amica curiae brief, Dkt. 156 , it is hereby ORDERED that Defendant shall file an opposition to the motion for leave to file, if any, on or before September 14, 2020. The Court does not expect Defendant to answer the arguments made in the proposed amica brief at this time but only to address whether the brief should be accepted for consideration. Signed by Judge Randolph D. Moss on 09/10/2020. (lcrdm1) (Entered: 09/10/2020) | ||
| 157 | Sep 10, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Opp. to Def.'s MSJ, # 2 Exhibit SRAMF, # 3 Exhibit Kornblith Decl., # 4 Exhibit A1, # 5 Exhibit B1, # 6 Exhibit B2, # 7 Exhibit C5, # 8 Exhibit C6, # 9 Exhibit C9, # 10 Exhibit C10, # 11 Exhibit C12, # 12 Exhibit C13, # 13 Exhibit C14, # 14 Exhibit C16, # 15 Exhibit C17, # 16 Exhibit C18, # 17 Exhibit C19, # 18 Exhibit C20, # 19 Exhibit C21, # 20 Exhibit D1, # 21 Exhibit D2, # 22 Exhibit D3, # 23 Exhibit D4, # 24 Exhibit D5, # 25 Exhibit D6, # 26 Exhibit E2, # 27 Exhibit G2, # 28 Exhibit G3, # 29 Exhibit G4, # 30 Exhibit G5, # 31 Exhibit G6, # 32 Text of Proposed Order)(Powers, MaryEllen) (Entered: 09/10/2020) |
| Sep 11, 2020 | MINUTE ORDER: Upon consideration of the parties' joint motion for leave to file under seal, Dkt. 157 , it is hereby ORDERED that the motion is GRANTED. The parties are ORDERED to refile on the public docket Plaintiffs' opposition to Defendant's motion for summary judgment on Count IV of the third amended complaint, the declaration of Russell Kornblith in opposition to Defendant's motion for summary judgment, Plaintiffs' statement of responsive and additional material facts, and accompanying exhibits with redactions consistent with this order. Signed by Judge Randolph D. Moss on 09/11/2020. (lcrdm1) (Entered: 09/11/2020) | ||
| 158 | Sep 11, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Reply MSJ, # 2 Exhibit Reply SUMF, # 3 Exhibit Suppl. Decl. of Lori Bounds, # 4 Exhibit Suppl. Decl. of Traci Lovitt, # 5 Exhibit Chase Ex. 3, # 6 Exhibit Chase Ex. 5, # 7 Exhibit Chase Ex. 6, # 8 Exhibit Chase Ex. 7, # 9 Exhibit Chase Ex. 8, # 10 Exhibit Chase Ex. 9, # 11 Exhibit Chase Ex. 10, # 12 Exhibit Chase Ex. 11, # 13 Exhibit Chase Ex. 12, # 14 Exhibit Chase Ex. 13, # 15 Text of Proposed Order)(Powers, MaryEllen) (Entered: 09/11/2020) |
| 159 | Sep 11, 2020 | View | REPLY to opposition to motion re 147 MOTION for Summary Judgment on Count IV (Equal Pay Act) (REDACTED PER COURT'S AUG. 3 MINUTE ORDER), 129 MOTION for Summary Judgment on Count IV (Equal Pay Act) (CORRECTED) filed by JONES DAY. (Attachments: # 1 Statement of Facts Reply, # 2 Declaration of Lori Bounds (Supplemental), # 3 Declaration of Traci Lovitt (Supplemental), # 4 Declaration of Sharyl Reisman (Supplemental), # 5 Declaration of Kate Wallace, # 6 Declaration of Terri Chase (Supplemental), # 7 Exhibit Chase 1, # 8 Exhibit Chase 2, # 9 Exhibit Chase 3, # 10 Exhibit Chase 4, # 11 Exhibit Chase 5, # 12 Exhibit Chase 6, # 13 Exhibit Chase 7, # 14 Exhibit Chase 8, # 15 Exhibit Chase 9, # 16 Exhibit Chase 10, # 17 Exhibit Chase 11, # 18 Exhibit Chase 12, # 19 Exhibit Chase 13, # 20 Exhibit Chase 14, # 21 Exhibit Chase 15)(Powers, MaryEllen) (Entered: 09/11/2020) |
| 161 | Sep 11, 2020 | View | SEALED OPPOSITION filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS re 147 MOTION for Summary Judgment on Count IV (Equal Pay Act) (REDACTED PER COURT'S AUG. 3 MINUTE ORDER) (ztd); (SEE DOCKET ENTRY NO. 157 TO VIEW EXHIBITS.) (Entered: 09/15/2020) |
| 160 | Sep 14, 2020 | Request | RESPONSE re 156 MOTION for Leave to File Amica Curiae Brief filed by JONES DAY. (Powers, MaryEllen) (Entered: 09/14/2020) |
| Sep 14, 2020 | MINUTE ORDER: Upon consideration of Julia Sheketoff's motion to file an amica curiae brief, Dkt. 156 , it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Parties must file a response, if any, to the arguments in the amica curiae brief on or before September 28, 2020. Signed by Judge Randolph D. Moss on 09/14/2020. (lcrdm1) (Entered: 09/14/2020) | ||
| 162 | Sep 14, 2020 | Request | AMICUS BRIEF by JULIA SHEKETOFF. (ztd) (Entered: 09/15/2020) |
| Sep 15, 2020 | MINUTE ORDER: Upon consideration of Defendant's sealed motion, Dkt. 158 , to file provisionally under seal portions of Defendant's reply memorandum in support of motion for summary judgment on count IV (Equal Pay Act) and related documents, it is hereby ORDERED that Defendant's motion is GRANTED. It is further ORDERED that the Parties shall meet and confer and, on or before September 25, 2020, jointly file agreed-upon proposed redactions for each exhibit for which redactions are sought by either party. If any disputes remain pertaining to certain exhibits following the parties' conferral, each party shall also file, at the same time, separate copies of each disputed exhibit, including the proposed redactions that the party deems appropriate along with a corresponding explanation of the basis for the parties' dispute regarding each redaction upon which the parties cannot agree. The Court notes that "the starting point in considering a motion to seal court records is a 'strong presumption in favor of public access to judicial proceedings.'" EEOC v. National Children's Center, Inc., 98 F.3d 1406, 1409 (D.C. Cir. 1996) (quoting Johnson v. Greater Southeast Cmty. Hosp. Corp., 951 F.2d 1268, 1277 (D.C. Cir. 1991)). Signed by Judge Randolph D. Moss on 09/15/2020. (lcrdm1) (Entered: 09/15/2020) | ||
| 163 | Sep 15, 2020 | Request | SEALED REPLY TO OPPOSITION filed by JONES DAY re 147 MOTION for Summary Judgment on Count IV (Equal Pay Act) (REDACTED PER COURT'S AUG. 3 MINUTE ORDER) (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Statement of Facts, # 2 Declaration, # 3 Declaration, # 4 Exhibit Chase Ex 3, # 5 Exhibit Chase Ex 5, # 6 Exhibit Chase Ex 6, # 7 Exhibit Chase Ex 7, # 8 Exhibit Chase Ex 8, # 9 Exhibit Chase Ex 9, # 10 Exhibit Chase Ex 10, # 11 Exhibit Chase Ex 11, # 12 Exhibit Chase Ex 12, # 13 Exhibit Chase Ex 13)(ztd) (Entered: 09/15/2020) |
| 164 | Sep 16, 2020 | View | Memorandum in opposition to re 147 MOTION for Summary Judgment on Count IV (Equal Pay Act) (REDACTED PER COURT'S AUG. 3 MINUTE ORDER) (REDACTED PER COURT'S SEP. 11 MINUTE ORDER) filed by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (Attachments: # 1 Text of Proposed Order Denying Summary Judgment, # 2 Statement of Facts Response and Additional Facts, # 3 Declaration of Russell L. Kornblith, # 4 Exhibit A1, # 5 Exhibit A2, # 6 Exhibit A3, # 7 Exhibit B1, # 8 Exhibit B2, # 9 Exhibit B3, # 10 Exhibit B4, # 11 Exhibit B5, # 12 Exhibit C1, # 13 Exhibit C2, # 14 Exhibit C3, # 15 Exhibit C4, # 16 Exhibit C5, # 17 Exhibit C6, # 18 Exhibit C7, # 19 Exhibit C8, # 20 Exhibit C9, # 21 Exhibit C10, # 22 Exhibit C11, # 23 Exhibit C12, # 24 Exhibit C13, # 25 Exhibit C14, # 26 Exhibit C15, # 27 Exhibit C16, # 28 Exhibit C17, # 29 Exhibit C18, # 30 Exhibit C19, # 31 Exhibit C20, # 32 Exhibit C21, # 33 Exhibit C22, # 34 Exhibit C23, # 35 Exhibit C24, # 36 Exhibit D1, # 37 Exhibit D2, # 38 Exhibit D3, # 39 Exhibit D4, # 40 Exhibit D5, # 41 Exhibit D6, # 42 Exhibit D7, # 43 Exhibit D8, # 44 Exhibit D9, # 45 Exhibit D10, # 46 Exhibit E1, # 47 Exhibit E2, # 48 Exhibit E3, # 49 Exhibit F1, # 50 Exhibit F2, # 51 Exhibit G1, # 52 Exhibit G2, # 53 Exhibit G3, # 54 Exhibit G4, # 55 Exhibit G5, # 56 Exhibit G6)(Kornblith, Russell) (Entered: 09/16/2020) |
| 165 | Sep 25, 2020 | Request | SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JONES DAY (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit Reply re: MSJ, # 2 Exhibit Reply re: SRAMF, # 3 Exhibit Suppl. Bounds Decl., # 4 Exhibit Suppl. Lovitt Decl., # 5 Exhibit Chase Ex. 5, # 6 Exhibit Chase Ex. 6, # 7 Exhibit Chase Ex. 7, # 8 Exhibit Chase Ex. 8, # 9 Exhibit Chase Ex. 10, # 10 Exhibit Chase Ex. 11, # 11 Exhibit Chase Ex. 12, # 12 Exhibit Chase Ex. 13, # 13 Text of Proposed Order)(Powers, MaryEllen) (Entered: 09/25/2020) |
| 166 | Sep 28, 2020 | View | RESPONSE re 162 Amicus Brief filed by JONES DAY. (Powers, MaryEllen) (Entered: 09/28/2020) |
| 167 | Sep 30, 2020 | View | MOTION to Withdraw as Attorney by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Attachments: # 1 Text of Proposed Order Granting Motion to Withdraw Paul Blankenstein as Counsel of Record)(Mueting, Katie) (Entered: 09/30/2020) |
| Oct 1, 2020 | MINUTE ORDER: Upon consideration of Plaintiffs' motion to withdraw Paul Blankenstein as counsel of record, Dkt. 167 , the Court finds good cause has been shown for granting the motion. It is hereby ORDERED that the motion is GRANTED and further ORDERED that Paul Blankenstein be withdrawn as Plaintiffs' counsel in this matter. Signed by Judge Randolph D. Moss on 10/01/2020. (lcrdm1) (Entered: 10/01/2020) | ||
| Oct 1, 2020 | MINUTE ORDER: Upon consideration of Parties' sealed joint motion for leave to file under seal, Dkt. 165 , it is hereby ORDERED that the motion is GRANTED. Parties are ORDERED to refile the exhibits, redacted as proposed in their motion, on the public docket. Signed by Judge Randolph D. Moss on 10/01/2020. (lcrdm1) (Entered: 10/01/2020) | ||
| 168 | Oct 1, 2020 | Request | SEALED REPLY TO OPPOSITION filed by JONES DAY re 147 MOTION for Summary Judgment on Count IV (Equal Pay Act) (REDACTED PER COURT'S AUG. 3 MINUTE ORDER) (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Statement of Facts, # 2 Exhibit Suppl. Bounds Decl, # 3 Exhibit Suppl. Lovitt Decl, # 4 Exhibit Chase Ex. 6, # 5 Exhibit Chase Ex. 7, # 6 Exhibit Chase Ex. 8, # 7 Exhibit Chase Ex. 10, # 8 Exhibit Chase Ex. 11, # 9 Exhibit Chase Ex. 12, # 10 Exhibit Chase Ex. 13)(ztd) (Entered: 10/02/2020) |
| 169 | Oct 5, 2020 | View | REPLY to opposition to motion re 147 MOTION for Summary Judgment on Count IV (Equal Pay Act) (REDACTED PER COURT'S AUG. 3 MINUTE ORDER) (REDACTED PER COURT'S OCT. 1 MINUTE ORDER) filed by JONES DAY. (Attachments: # 1 Statement of Facts Reply, # 2 Declaration of Lori Bounds (Supplemental), # 3 Declaration of Traci Lovitt (Supplemental), # 4 Declaration of Sharyl Reisman (Supplemental), # 5 Declaration of Kate Wallace, # 6 Declaration of Terri Chase (Supplemental), # 7 Exhibit Suppl. Chase Ex. 1, # 8 Exhibit Suppl. Chase Ex. 2, # 9 Exhibit Suppl. Chase Ex. 3, # 10 Exhibit Suppl. Chase Ex. 4, # 11 Exhibit Suppl. Chase Ex. 5, # 12 Exhibit Suppl. Chase Ex. 6, # 13 Exhibit Suppl. Chase Ex. 7, # 14 Exhibit Suppl. Chase Ex. 8, # 15 Exhibit Suppl. Chase Ex. 9, # 16 Exhibit Suppl. Chase Ex. 10, # 17 Exhibit Suppl. Chase Ex. 11, # 18 Exhibit Suppl. Chase Ex. 12, # 19 Exhibit Suppl. Chase Ex. 13, # 20 Exhibit Suppl. Chase Ex. 14, # 21 Exhibit Suppl. Chase Ex. 15)(Powers, MaryEllen) (Entered: 10/05/2020) |
| Oct 16, 2020 | NOTICE of Hearing: Telephone Conference set for 10/19/2020, at 10:00 AM, before Judge Randolph D. Moss, to address discovery dispute. The parties are to utilize the same teleconference number and access code as before.(kt) (Entered: 10/16/2020) | ||
| Oct 19, 2020 | Minute Entry for proceedings held before Judge Randolph D. Moss: Telephone Conference held on 10/19/2020 as to discovery dispute. Plaintiffs' reports due by 12/1/2020; Defendant's reports due by 1/6/2021; Plaintiffs' rebuttal reports due by 2/12/2021; Expert discovery to close by 3/5/2021. For the reasons stated on the record, the Court grants Plaintiffs' request as to the spreadsheets. (Court Reporter: Jeff Hook.) (kt) (Entered: 10/19/2020) | ||
| 170 | Oct 22, 2020 | Request | TRANSCRIPT OF TELEPHONE CONFERENCE before Judge Randolph D. Moss held on October 19, 2020. Page Numbers: 1 - 64. Date of Issuance: October 22, 2020. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court re porter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 11/12/2020. Redacted Transcript Deadline set for 11/22/2020. Release of Transcript Restriction set for 1/20/2021.(Hook, Jeff) (Entered: 10/22/2020) |
| 171 | Oct 29, 2020 | Request | ENTERED IN ERROR. . . . .NOTICE of Appearance by Deborah Kristine Marcuse on behalf of SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Marcuse, Deborah) Modified on 10/30/2020 (ztd). (Entered: 10/29/2020) |
| 172 | Oct 29, 2020 | Request | MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Clare J. Horan, Filing fee $ 100, receipt number ADCDC-7775797. Fee Status: Fee Paid. by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Attachments: # 1 Declaration of Clare J. Horan, # 2 Text of Proposed Order)(Marcuse, Deborah) (Entered: 10/29/2020) |
| Oct 30, 2020 | MINUTE ORDER: Upon consideration of Plaintiffs' Motion for Admission Pro Hac Vice, Dkt. 172 , it is hereby ORDERED that the motion is GRANTED. Clare J. Horan is hereby granted leave to appear pro hac vice in this case. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to to LCvR 83.6(a)/LCrR 44.5(a). Click for Instructions. Signed by Judge Randolph D. Moss on 10/30/20 20. (lcrdm1) (Entered: 10/30/2020) | ||
| Oct 30, 2020 | NOTICE OF ERROR re 171 Notice of Appearance; emailed to dmarcuse@sanfordheisler.com, cc'd 18 associated attorneys -- The PDF file you docketed contained errors: 1. Invalid attorney signature, 2. Please refile document, 3. Counsel must use their own passwords to file. You can not file on behalf of others. (ztd, ) (Entered: 10/30/2020) | ||
| 173 | Oct 30, 2020 | Request | NOTICE of Appearance by Whittney Barth on behalf of SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Barth, Whittney) (Entered: 10/30/2020) |
| 174 | Nov 2, 2020 | Request | MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Kathleen Wallace, Filing fee $ 100, receipt number ADCDC-7787529. Fee Status: Fee Paid. by JONES DAY (Attachments: # 1 Declaration, # 2 Text of Proposed Order)(Powers, MaryEllen) (Entered: 11/02/2020) |
| Nov 3, 2020 | MINUTE ORDER: Upon consideration of Defendant's Motion for Admission Pro Hac Vice of Kathleen Wallace, Dkt. 174 , it is hereby ORDERED that the motion is GRANTED. Kathleen Wallace is hereby granted leave to appear pro hac vice in this case. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to to LCvR 83.6(a)/LCrR 44.5(a). Click for Instructions. Signed by Judge Randol ph D. Moss on 11/03/2020. (lcrdm1) (Entered: 11/03/2020) | ||
| 175 | Nov 6, 2020 | Request | NOTICE of Appearance by Adrian Wager-Zito on behalf of JONES DAY (Wager-Zito, Adrian) (Entered: 11/06/2020) |
| 176 | Nov 9, 2020 | Request | NOTICE of Appearance by Kate Wallace on behalf of JONES DAY (Wallace, Kate) (Entered: 11/09/2020) |
| 177 | Nov 10, 2020 | Request | NOTICE of Appearance by Clare J. Horan on behalf of SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Horan, Clare) (Entered: 11/10/2020) |
| 178 | Nov 17, 2020 | Request | Joint MOTION for Extension of Time to Submit Industrial and Organizational Psychologist Expert Reports by JONES DAY (Attachments: # 1 Text of Proposed Order)(Chase, Terri) (Entered: 11/17/2020) |
| Nov 19, 2020 | MINUTE ORDER: Upon consideration of Parties' joint motion to amend the schedule for psychologist expert reports, Dkt. 178 , it is hereby ORDERED that the motion is GRANTED. Plaintiffs' industrial and organizational psychologist's report shall now be due on or before December 8, 2020. Defendant's industrial and organizational psychologist's opposition report shall now be due on or before January 13, 2021. Plaintiff's industrial and organizational psychologist's rebuttal report shall be due on or before February 19, 2021. Signed by Judge Randolph D. Moss on 11/19/2020. (lcrdm1) (Entered: 11/19/2020) | ||
| 179 | Dec 1, 2020 | Request | MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Kate MacMullin, Filing fee $ 100, receipt number ADCDC-7902299. Fee Status: Fee Paid. by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS (Attachments: # 1 Declaration Declaration ISO Pro Hac Vice Admission, # 2 Text of Proposed Order Proposed Order Granting Pro Hac Vice Admission)(Marcuse, Deborah) (Entered: 12/01/2020) |
| Dec 1, 2020 | MINUTE ORDER: Upon consideration of Plaintiffs' Motion for Admission Pro Hac Vice, Dkt. 179 , it is hereby ORDERED that the motion is GRANTED. Kate MacMullin is hereby granted leave to appear pro hac vice in this case. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to to LCvR 83.6(a)/LCrR 44.5(a). Click for Instructions. Signed by Judge Randolph D. Moss on 12/01/20 20. (lcrdm1) (Entered: 12/01/2020) | ||
| 180 | Dec 4, 2020 | Request | NOTICE of Appearance by Kate MacMullin on behalf of All Plaintiffs (MacMullin, Kate) (Entered: 12/04/2020) |
| Dec 7, 2020 | MINUTE ORDER: In light of recent communications between the parties and the Deputy Clerk of Court regarding developments in the case, it is hereby ORDERED that the parties shall meet and confer and file a joint status report on or before December 14, 2020. Signed by Judge Randolph D. Moss on 12/07/2020. (lcrdm1) (Entered: 12/07/2020) | ||
| 181 | Dec 14, 2020 | View | Joint STATUS REPORT by JONES DAY. (Chase, Terri) (Entered: 12/14/2020) |
| Dec 15, 2020 | MINUTE ORDER: Upon consideration of the parties' joint status report, Dkt. 181 , it is hereby ORDERED that the motion to certify class conditionally under the Equal Pay Act, Dkt. 145 , is DENIED as moot. It is further ORDERED that the parties shall adhere to the following schedule. The parties shall file a stipulation identifying the claims voluntarily dismissed and those claims that remain in the action on or before December 21, 2020. Fact discovery shall close on April 30, 2021. Defendant shall file a motion for summary judgment on or before June 4, 2021; Plaintiffs shall file an opposition on or before July 15, 2021; and Defendant shall file a reply on or before August 5, 2021. Signed by Judge Randolph D. Moss on 12/15/2020. (lcrdm1) (Entered: 12/15/2020) | ||
| 182 | Dec 21, 2020 | View | STIPULATION of Dismissal by JONES DAY. (Attachments: # 1 Text of Proposed Order)(Chase, Terri) (Entered: 12/21/2020) |
| 183 | Dec 30, 2020 | View | ORDER: Upon consideration of the parties' stipulation of dismissal, Dkt. 182 , it is hereby ORDERED that the claims stipulated by the parties are DISMISSED. See attached order for details. Signed by Judge Randolph D. Moss on 12/30/2020. (lcrdm1) (Entered: 12/30/2020) |
| 184 | Jan 20, 2021 | View | STIPULATION re 57 Answer to Amended Complaint by SAIRA DRAPER, KATRINA HENDERSON, ANDREA MAZINGO, JACLYN STAHL, NILAB RAHYAR TOLTON, MEREDITH WILLIAMS. (Attachments: # 1 Text of Proposed Order)(Mueting, Katie) (Entered: 01/20/2021) |
| Jan 21, 2021 | MINUTE ORDER: Upon consideration of the parties' stipulation, Dkt. 184 , regarding Defendant's answer, Dkt. 57 , to the third amended complaint, Dkt. 41 , it is hereby ORDERED that Defendant is GRANTED leave to make the amendments and withdrawals set forth in the stipulation. Defendant is further ORDERED to file the amended answer on the docket. Signed by Judge Randolph D. Moss on 01/21/2021. (lcrdm1) (Entered: 01/21/2021) |